Changpeng Zhao was released in September 2024 after a four-month sentence. The five-year DOJ corporate monitorship of Binance — imposed as part of the historic $4.3bn plea agreement — is now in its second year. We review the monitor's quarterly reports and the structural reforms underway.
The United States Department of Justice's corporate monitorship of Binance, the world's largest cryptocurrency exchange by trading volume, entered its second year in November 2025. The monitorship was imposed as part of a historic $4.3 billion plea agreement in November 2023, in which Binance admitted to violations of the Bank Secrecy Act, the International Emergency Economic Powers Act, and the Money Laundering Control Act.
The Plea Agreement Structure
Under the terms of the plea agreement approved by Judge Richard A. Jones of the Western District of Washington, Binance agreed to a five-year corporate monitorship administered by the DOJ's Money Laundering and Asset Recovery Section (MLARS). The monitorship requires Binance to implement comprehensive anti-money laundering (AML) and sanctions compliance programs, submit to quarterly independent audits, and report all suspicious activity to FinCEN.
Founder Accountability
Changpeng Zhao, Binance's founder and former CEO, pleaded guilty to a single count of failure to maintain an effective AML program under 31 U.S.C. § 5318(h). He was sentenced to four months in federal custody, which he served from May to September 2024 at the Federal Detention Center in SeaTac, Washington. Zhao was released on September 27, 2024, and remains subject to a $175 million personal recognizance bond. He is permanently barred from any management role at Binance under the terms of the plea agreement.
The Monitor's Q1 2025 Report
The first independent monitor's report, filed under seal in March 2025 and summarized in a public docket entry, identified 14 "material compliance deficiencies" in Binance's transaction monitoring systems. Key findings included:
- Inadequate screening of approximately 2.7 million transactions originating from jurisdictions subject to OFAC sanctions between January and December 2024
- Failure to file Suspicious Activity Reports (SARs) within the statutory 30-day window for 43% of identified suspicious transactions
- Gaps in beneficial ownership verification for institutional clients, with 18% of corporate account records lacking required ultimate beneficial owner (UBO) documentation
Structural Reforms
Binance has implemented a series of structural reforms under the monitorship including: the appointment of a new Global Head of Compliance with direct reporting lines to the board; deployment of a new transaction monitoring platform (Chainalysis Reactor + custom rules engine); a threefold increase in compliance staffing to 1,200 employees; and mandatory blockchain analytics training for all trading desk personnel.
The Fine and Forfeiture
The $4.3 billion penalty consists of $1.8 billion in criminal fines, $1.5 billion in forfeiture, and $1.0 billion in disgorgement to the Financial Crimes Enforcement Network (FinCEN). As of November 2025, Binance has paid $3.1 billion of the total, with the remaining $1.2 billion due in installments through November 2026.
Market Impact
Despite the legal sanctions, Binance's market share in spot crypto trading remained above 38% in Q4 2025, according to data from CoinMarketCap and Kaiko. The exchange processed approximately $1.7 trillion in trading volume in the first three quarters of 2025, a 12% increase year-over-year.
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