In the largest corporate criminal resolution that included charges against a company’s CEO, Binance Holdings Limited entered into a plea agreement on November 21, 2023, with two DOJ sections and the U.S. Attorney’s Office for the Western District of Washington. Binance agreed to pay approximately $4.3 billion for violations related to the Bank Secrecy Act (BSA), failure to register as a money transmitting business and violations of the International Emergency Economic Powers Act. Binance CEO Changpeng Zhao pleaded guilty to failing to maintain an effective anti-money laundering program, in violation of the BSA. Samuel Lim, Binance’s former CCO,
agreed to a proposed consent order with the U.S. Commodity Futures Trading Commission for willfully aiding and abetting Binance’s numerous violations of the Commodities Exchange Act. This article examines the case with insights from Alston & Bird LLP, Sadis & Goldberg LLP, Incite Consulting and Wolf Global. See “Is Coinbase a Warning to Other Crypto Players?
” (Feb. 15, 2023).