DOJ scrutinizes Binance compliance with its 2023 settlement

Belle Femme Emmo / Wikimedia Commons (CC BY-SA 4.0)

DOJ scrutinizes Binance compliance with its 2023 settlement

Federal prosecutors are examining whether the exchange let Iran-linked transactions slip through after agreeing to clean up its act

The US Department of Justice is reviewing whether Binance has lived up to the settlement it signed with American authorities in November 2023.

The review is focused on possible violations of US sanctions against Iran. Prosecutors are examining whether Binance knowingly processed transactions that its systems should have blocked.

What prosecutors are looking at

The Manhattan US Attorney’s Office is leading the work alongside the DOJ’s Criminal Division. Their focus is Binance’s compliance machinery and how well it actually performs.

The key detail is timing. Investigators are reportedly concentrating on activity that took place after the 2023 settlement, not before it.

At the center of the scrutiny are transactions involving Hong Kong entities. Those entities are accused of helping move payments tied to Iranian oil sales.

On September 15, 2026, the DOJ filed a civil forfeiture action seeking $61 million in digital assets connected to those flows. Binance was not named as a defendant in that action.

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The broader investigations resurfaced in late September 2026, following reports of Iran-linked transaction flows.

Binance’s response

Binance has said it maintains a zero-tolerance policy toward sanctions violations. The exchange says it remains committed to compliance.

As evidence, Binance points to its practice of offboarding accounts linked to suspicious activity. It removed such accounts in August 2025 and again in January 2026.

How we got here

The November 2023 settlement was one of the largest corporate penalties in crypto history. Binance admitted to violating the Bank Secrecy Act, the core US anti-money laundering law.

Total penalties exceeded $4.3 billion. That figure included $2.51 billion in forfeitures and a $1.81 billion fine paid to the DOJ.

Binance agreed to a three-year DOJ monitorship focused on anti-money laundering compliance. It was also required to exit the US market.

In 2024, Binance appointed two independent monitors. Forensic Risk Alliance took a three-year oversight role, while Sullivan & Cromwell took on a five-year assignment.

Founder Changpeng Zhao pleaded guilty in 2023 and was fined $50 million. He also stepped down as CEO.

What this means

The outcome is far from settled. Binance has not been charged with anything new, and it was not a defendant in the September forfeiture case.

The things to watch are fairly clear. First, whether the DOJ’s review produces formal findings about Binance’s post-settlement conduct. Second, whether the $61 million forfeiture case surfaces more detail about how the Hong Kong entities moved money.

Third, how the monitorships play out. Forensic Risk Alliance’s three-year term and Sullivan & Cromwell’s five-year term give regulators a built-in window to keep watching.

Disclosure: This article was edited by John Chen. For more information on how we create and review content, see our Editorial Policy.
DOJ scrutinizes Binance compliance with its 2023 settlement
DOJ scrutinizes Binance compliance with its 2023 settlement

Federal prosecutors are examining whether the exchange let Iran-linked transactions slip through after agreeing to clean up its act

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Belle Femme Emmo / Wikimedia Commons (CC BY-SA 4.0)

The US Department of Justice is reviewing whether Binance has lived up to the settlement it signed with American authorities in November 2023.

The review is focused on possible violations of US sanctions against Iran. Prosecutors are examining whether Binance knowingly processed transactions that its systems should have blocked.

What prosecutors are looking at

The Manhattan US Attorney’s Office is leading the work alongside the DOJ’s Criminal Division. Their focus is Binance’s compliance machinery and how well it actually performs.

The key detail is timing. Investigators are reportedly concentrating on activity that took place after the 2023 settlement, not before it.

At the center of the scrutiny are transactions involving Hong Kong entities. Those entities are accused of helping move payments tied to Iranian oil sales.

On September 15, 2026, the DOJ filed a civil forfeiture action seeking $61 million in digital assets connected to those flows. Binance was not named as a defendant in that action.

Advertisement

The broader investigations resurfaced in late September 2026, following reports of Iran-linked transaction flows.

Binance’s response

Binance has said it maintains a zero-tolerance policy toward sanctions violations. The exchange says it remains committed to compliance.

As evidence, Binance points to its practice of offboarding accounts linked to suspicious activity. It removed such accounts in August 2025 and again in January 2026.

How we got here

The November 2023 settlement was one of the largest corporate penalties in crypto history. Binance admitted to violating the Bank Secrecy Act, the core US anti-money laundering law.

Total penalties exceeded $4.3 billion. That figure included $2.51 billion in forfeitures and a $1.81 billion fine paid to the DOJ.

Binance agreed to a three-year DOJ monitorship focused on anti-money laundering compliance. It was also required to exit the US market.

In 2024, Binance appointed two independent monitors. Forensic Risk Alliance took a three-year oversight role, while Sullivan & Cromwell took on a five-year assignment.

Founder Changpeng Zhao pleaded guilty in 2023 and was fined $50 million. He also stepped down as CEO.

What this means

The outcome is far from settled. Binance has not been charged with anything new, and it was not a defendant in the September forfeiture case.

The things to watch are fairly clear. First, whether the DOJ’s review produces formal findings about Binance’s post-settlement conduct. Second, whether the $61 million forfeiture case surfaces more detail about how the Hong Kong entities moved money.

Third, how the monitorships play out. Forensic Risk Alliance’s three-year term and Sullivan & Cromwell’s five-year term give regulators a built-in window to keep watching.

Disclosure: This article was edited by John Chen. For more information on how we create and review content, see our Editorial Policy.