FTC v. Binance Court Filing, retrieved on March 27, 2023, is part of HackerNoon’s Legal PDF Series. You can jump to any part in this filing here. This is the table of links with all parts.
Case Number: 1:23-cv-01887
Plaintiff: FTC
Defendant: Binance
Judge: Manish Suresh Shah
Filing Date: March 27, 2023
Location: IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
TABLE OF CONTENTS
COMPLAINT FOR INJUNCTIVE AND OTHER EQUITABLE RELIEF AND CIVIL MONETARY PENALTIES UNDER THE COMMODITY EXCHANGE ACT AND COMMISSION REGULATIONS
III. PARTIES
IV. RELEVANT STATUTORY BACKGROUND AND LEGAL FRAMEWORK
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A. Applicable Provisions Under the Commodity Exchange Act and Regulations
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B. Provisions Authorizing Imposition of Derivative Liability Under the CEA
V. FACTS
- A. Overview of the Binance Platform and Operations
- B. Relevant Financial Products Offered by Binance
- C. Binance’s Proprietary Trading Activity on Binance
- D. Binance’s Presence in the United States
- E. Zhao Controls Binance and Operates Binance as a Common Enterprise
- F. Binance’s Superficial Efforts to Limit Trading by United States Customers and Internal Recognition That Its Compliance Program Was Just “For Show”
- G. Binance Was Aware of United States Regulatory Requirements but Ignored Them
- H. Binance Has Guided United States Customers to Evade Its Compliance Controls Through the Use of VPNs and Other Creative Means
- I. Binance Has Directed Its VIP Customers to Evade Compliance Controls, Including Through Submission of “New” KYC Documents
- J. Binance Knowingly Concealed the Presence of United States Customers In Internal Documents and Data
- K. Binance Has Relied On “Brokers” to Introduce Customers to the Binance Platform Without Effective Access Controls
- L. Examples of Market Participants Currently Trading on Binance and Binance’s Efforts to Help Them Evade Its Compliance Controls
VI. VIOLATIONS OF THE COMMODITY EXCHANGE ACT AND REGULATIONS
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