In November 2023, the world’s largest cryptocurrency exchange, Binance, agreed to pay $4.3 billion, the largest penalty in U.S. Treasury and FinCEN history, to resolve DOJ, CFTC, FinCEN and OFAC investigations into allegations that it operated as an unregistered money transmitter and willfully violated anti-money laundering (“AML”) and sanctions laws. “Binance and CEO Plead Guilty to Federal Charges in $4B Resolution,” U.S. Justice Department (Nov. 21, 2023).

Matthew Biben, partner at King & Spalding.

Binance’s penalty may have been singularly large, but the cryptocurrency exchange was not the only cryptocurrency provider to have faced a significant AML enforcement action in the recent past for allegedly failing to adequately comply with U.S. AML laws.

Olivia Radin, partner at King & Spalding.