Section 951 Power Creep

Internal DOJ memos show the Justice Department repurposed Section 951 of the Financial Institutions Reform, Recovery, and Enforcement Act (a tool aimed at fraud against banks) to pressure banks to drop lawful customers. That expansion of civil‑enforcement authority turned subpoenas and reputational‑risk guidance into de‑facto regulatory coercion against entire lines of legal business. — If narrow enforcement statutes can be stretched into broad economic control tools, it raises structural questions about agency limits, bank gatekeeping power, and democratic oversight.