The US Department of Justice is reviewing whether Binance Holdings Ltd. violated its landmark November 2023 settlement, focusing on potential Iran sanctions violations. Tysen Duva of the DOJ's criminal division confirmed the compliance review, which examines post-settlement transactions. The probe follows a September 15, 2026 civil forfeiture action targeting $61 million in digital assets linked to Hong Kong entities involved in Iranian oil sales. Binance maintains a zero-tolerance sanctions policy.
DOJ review of Binance compliance
- ▪The US Department of Justice is reviewing whether Binance Holdings Ltd. breached its November 2023 settlement agreement with American authorities, which included a $4.3 billion penalty
- ▪The Manhattan US Attorney’s Office and the Department of Justice’s Criminal Division are leading the review of Binance’s compliance with its November 2023 settlement, focusing on Binance's post-settlement compliance machinery and performance
- ▪Tysen Duva, head of the Department of Justice's criminal division, confirmed the review of Binance Holdings Ltd.'s compliance with its 2023 settlement but declined to discuss specifics or state that Binance was in violation
- ▪The Department of Justice's review of Binance Holdings Ltd. is focused on potential violations of US sanctions against Iran
Binance compliance measures
- ▪Binance accepted increased compliance controls as part of its 2023 settlement agreement with the United States government
- ▪Binance stated it maintains a zero-tolerance policy toward sanctions violations and pointed to its offboarding of accounts linked to sanctions-related suspicious activity in August 2025 and January 2026
Civil forfeiture action over Iranian oil
- ▪On September 15, 2026, the Department of Justice filed a civil forfeiture action seeking $61 million in digital assets connected to Hong Kong entities accused of moving payments for Iranian oil sales
- ▪Binance was not named as a defendant in the September 15, 2026 civil forfeiture action targeting Hong Kong entities linked to Iranian oil sales, involving $61 million in digital assets
Terms of the 2023 settlement
- ▪Under Binance's November 2023 settlement, Binance admitted to violating the Bank Secrecy Act, agreed to pay over $4.3 billion in penalties, and was required to exit the US market
- ▪The $4.3 billion Binance penalty from the November 2023 settlement included $2.51 billion in forfeitures and a $1.81 billion fine paid to the Department of Justice
Guilty plea of Changpeng Zhao
- ▪Binance founder Changpeng Zhao pleaded guilty in 2023, was fined $50 million, and stepped down as the chief executive officer of the cryptocurrency exchange
- ▪The 2023 guilty plea of Changpeng Zhao was part of the broader legal actions against Binance that led to the landmark $4.3 billion corporate settlement in November 2023
Independent compliance monitorships
- ▪In 2024, Binance appointed Forensic Risk Alliance for a three-year monitorship and Sullivan & Cromwell for a five-year monitorship to oversee anti-money laundering compliance
- ▪The independent monitorships of Forensic Risk Alliance and Sullivan & Cromwell, established under Binance's 2023 settlement, give regulators a built-in window to monitor Binance's compliance
Debatable claims
- ▪The DOJ's ongoing scrutiny of Binance's post-settlement compliance is justified
- ▪Cryptocurrency exchanges should be held strictly liable for transactions with sanctioned counterparties
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