Zhao’s location is typically kept secret, unless he is making a public appearance, and Lim is reportedly in Singapore. or within easy reach of its law-enforcement agencies. in December 2022 and is under house arrest in Stanford, California while awaiting trial, neither Zhao or Lim are in the U.S. Unlike former FTX CEO Sam Bankman-Fried, who was extradited to the U.S. Person.” Following numerous telephone conferences with Binance personnel concerning their “corporate structure,” Trading Firm A, again with the assistance of Binance personnel, opened a “new” account held by a different nominee shell entity in April 2021.”ĭespite the numerous details in this complaint, its long-term impact remains to be determined. In one such instance in December 2020, “Binance sent Trading Firm A an email that stated that Trading Firm A had “identified as a U.S. trading accounts to individuals located in jurisdictions beyond the reach of American law enforcement. The firm also helped institutional customers set up shell corporations or transfer U.S. If they figure it out on their own, its fine.” Lim flagged a passage in the VIP Handling policy for his colleagues that further explained: “We cannot teach users how to circumvent the controls. If user doesn’t get the hint, indicate that IP is the sole reason why he/she can’t use. maintain access to the platform.įor instance, the company’s VIP Handling Policy “instructed its personnel to “nform the user that the reason why he/she cant use our is because his/her IP is detected as US IP. The most striking parts of the complaint illustrate steps that Binance allegedly took, directed by Lim and under the guidance of Zhao, to help its most important clients in the U.S. In reality, Binance simply added a pop-up window on its website that appeared when customers attempted to log in from an IP address associated with the United States.” However, the pop-up did not stop customers from logging into accounts. customers, the complaint noted that in September 2019, “Binance claimed it had begun to block customers based on their internet protocol (“IP”) address. With regard to not following through on public plans to ban U.S. If Binance forces mandatory KYC, then will be VERY VERY happy.” Additionally, “Lim acknowledged in February 2020 that Binance had a financial incentive to avoid subjecting customers to meaningful KYC procedures, as Zhao believed that if Binance’s compliance controls were “too stringent” then “o users will come.” Another passage in the complaint reads, “i think cz understands that there is risk in, but I believe this is something which concerns our firm and its survivability. com,” said Lim in a January 2019 text conversation in the complaint, referring to the exchange’s homepage for its international exchange. It suggests that this was all done to satisfy Zhao’s desire to maintain market share in a key jurisdiction. laws and regulations, but it willfully failed to follow through with efforts to block American customers and even provided guidance on how its employees could conceal them from regulators and assist them in maintaining access to the platform. The colorfully worded 75-page complaint argues that Binance not only serviced U.S.
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