In the largest corporate criminal resolution that included charges against a company’s CEO, Binance Holdings Limited entered into a plea agreement recently 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, failure to register as a money transmitting business and violations of the International Emergency Economic Powers Act. Samuel Lim, Binance’s former CCO, also
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 cases and their implications, and offers practical guidance on using compliance to rebuild trust in the crypto business from Alston & Bird, Sadis & Goldberg, Incite Consulting and Wolf Global. See “Is Coinbase a Warning to Other Crypto Players?
” (Feb. 22, 2023).