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Web3 builders are only starting to realize the importance of sustainable and meaningful web3 marketing. There are web3 marketing companies and tools that are now helping web3 projects achieve traction. Another aspect of web3 that’s growing rapidly is the involvement of more women in this space. To discuss all of this, I had the opportunity to interview Victoria Vaughan, the co-founder of a marketing and PR firm InCryptoLand and the former CEO of Cointelegraph. Let’s dive in. Q. Hello Victoria, it’s great to be talking with you. Can you please introduce yourself, and share your professional journey with our readers? Hello, and thank you for having me! I'm Victoria Vaughan, and I am a co-founder of , a premier PR and marketing agency for the Web3 and tech sectors. InCryptoland My journey in Web3 started about nine years ago when I dived into the digital asset and blockchain world. I joined the Cointelegraph team as a project manager. Later, I was promoted to CEO and successfully grew the company to over nine million monthly readers across 10 languages. Impressive, right? But it's a team effort, trust me! Along the way, I've collaborated with some of the industry's most influential brands like Coinmarketcap, Etoro, Moonpay, and OKX. These collaborations expanded my expertise in growth hacking, marketing, and business development. Before all this blockchain excitement, I was deeply rooted in the tech scene, working for a tech startup as a product manager. So, you can say I've seen the industry from various angles, which has been super helpful in my current role as a tech PR agency co-founder. Q. Before we talk about InCryptoland, tell us how Web3 marketing agencies can solve the problems that Web3 companies face. Are PR firms an essential component of the Web3 ecosystem? If so, why? Yes, I think PR firms are absolutely essential in Web3. In a highly competitive blockchain ecosystem, you need a specialized marketing strategy. A tech-savvy PR agency can connect you with the right partners and investors while providing you with crucial media coverage. This makes the path to deal-closing and client acquisition much smoother. But it’s more than just PR. Crypto marketing agencies bring in a whole arsenal of growth hacking techniques. We're talking Twitter spaces, Discord AMAs, and some strategic Twitter shilling to grow your followers with minimum spend. Plus, a robust content marketing campaign can kill two birds with one stone: it boosts your SEO ranking and educates potential clients, essentially greasing the wheels for your business development. And let's not overlook the value of expertise. An experienced crypto marketing team brings a wealth of knowledge to your project, helps you sidestep common pitfalls, and executes effective campaigns. They've got connections too; a trusted network of influencers and partners that can take your project visibility to another level. Working directly with influencers can be a hit or miss, but agencies can pick the right ones to amplify your message. So, all in all, it's a win-win. Q. The volatile crypto market makes it difficult to run any Web3 company. How should someone build a team, develop a strategy, and make a Web3 marketing company successful? I totally get what you're saying about the rollercoaster ride that is the crypto market. So, first and foremost, you've got to be nimble with your financial planning. The ups and downs are wild; some companies go on a hiring spree in a bull market and then, bam, they're toast in a bear market. The key is to stay agile and adjust your strategy in real-time based on market conditions. On the subject of teams — I think a strong team is non-negotiable. You want a mix of people who are deep into Web3 but also some who come from more traditional sectors. That blend can help you craft a balanced strategy that's got both innovation and tested wisdom. Partnerships are the cherry on top; they bring cross-marketing opportunities and long-term support, which are gold in this fast-paced landscape. Now, the bear market isn't just about surviving; it's a land of opportunity. Companies that stay transparent and keep the conversation going with their community during the rough patches end up building trust and credibility. Not to mention, PR and marketing opportunities actually multiply. News outlets are more receptive, influencers are keen to partner, and the advertising costs are generally lower. So, it's all about turning challenges into stepping stones, really. Q. Tell us about InCryptoland and how it helps Web3 businesses. What are the fundamental working principles of your marketing agency? InCryptoland focuses on organic PR campaigns, social media management, and community growth. Our agency also developed a wide network of selected channels for media buy campaigns. What really excites us is collaborating with founders with a burning passion for meaningful causes and advanced technology products. For their PR campaigns, the strategy leans heavily into authentic storytelling that resonates with the audience and highlights the expertise of the team. ICL's guiding principles are Drive, Excellence, and Commitment. These principles really shape the way we approach each project. From crafting the ideal PR pitch to building up a strong community around a client's vision, our aim is to give it our all. We're continually seeking the best opportunities for reaching audiences and driving engagement in this fast-paced Web3 landscape. And speaking of capturing attention, our clients have been featured in the most recognized high-profile publications, like the New York Times, WSJ, Associated Press, USA Today, Cointelegraph, and Coindesk. So, we know a thing or two about getting a story out there in a way that strikes. Our experience spans different verticals of Web3 from DeFi to NFTs, infrastructural protocols to AI, and general tech. This helps us to know what works and what doesn’t. We use these insights to help clients avoid common mistakes in their communications and focus on effective strategies instead. Q. You’ve been working in the Web3 space for almost a decade. What has been your experience as a woman in Web3? Do you have any suggestions and advice for budding women entrepreneurs in the Web3 domain? There is no doubt that navigating the Web3 space as a woman has its own unique challenges. While the industry is generally welcoming, the large networking events can sometimes feel like "boy's clubs." You often have to break the ice yourself, put your expertise on display, and then—finally—you get taken seriously. I've had my fair share of awkward moments where people thought I was there to just hand out flyers. But the silver lining? As you broaden your network, each event becomes easier. The faces get familiar, introductions happen more naturally, and the atmosphere becomes genuinely inviting. The evolving role of women in Web3 is so exciting to watch. There's more to this space than just crypto and blockchain; we're seeing women lead the charge in areas like digital art, fashion, and health. For instance, the rise of NFTs has been a game-changer, especially for female artists. They're not just participating; they're shaping the narrative, moving the industry beyond just financial applications. Advice for budding women entrepreneurs? First, find your tribe—initiatives like WOW, Mybff, and Boy's Club are doing awesome work in enhancing women's awareness of the industry. Second, don't be discouraged by the technical jargon and male-centric vibes; there's room for everyone's talent here. Organizations like UnicornDAO and AthenaDAO are setting brilliant examples by focusing on inclusivity and women's health. Lastly, for the industry itself, the roadmap to diversity is clear: more shared stories, women-centric educational platforms, and an unequivocal commitment to diversify from the top down. Let's keep that conversation going. Q. Do you have any last comments on the current state of the Web3 industry? Where do you see it in the next three to five years? What will be the role of Web3 marketing firms in the coming years in shaping the overall industry? Honestly, the bear market often acts like a litmus test. It separates those who are genuinely committed to building something meaningful from the ones who are just riding the hype train. Remember, some of the most groundbreaking companies were born during downturns. Looking forward, regulation is inevitably coming down the pipeline. And while some might see that as a damper, I think it'll actually make the industry less of a wild west, which could attract more serious investment and innovation. We're already seeing AI making inroads into Web3, and that's a trend I only expect to accelerate. I also believe the infrastructural projects will grow a lot during the next several years. They're the bedrock that'll support the flashy apps and services everyone loves. So, where do Web3 marketing firms fit into all of this? As the industry matures, the role of specialized marketing agencies will only become more crucial. They'll help navigate the regulatory landscape, tap into AI's potential, and spotlight those infrastructural gems. Essentially, we'll be the architects of perception, shaping how the world views and engages with Web3.

Importance of Web3 Marketing and Women in Web3: An Interview With Victoria Vaughan

Web3 মার্কেটিং এবং Web3 তে নারীর গুরুত্ব: ভিক্টোরিয়া ভনের সাথে একটি সাক্ষাৎকার

Bedeutung von Web3-Marketing und Frauen in Web3: Ein Interview mit Victoria Vaughan

Importancia del marketing Web3 y las mujeres en Web3: una entrevista con Victoria Vaughan

Importance du marketing Web3 et des femmes dans le Web3 : une entrevue avec Victoria Vaughan

वेब3 मार्केटिंग का महत्व और वेब3 में महिलाएं: विक्टोरिया वॉन के साथ एक साक्षात्कार

Web3 マーケティングと Web3 における女性の重要性: Victoria Vaughan へのインタビュー

Web3 마케팅의 중요성과 Web3에서의 여성: Victoria Vaughan과의 인터뷰

Importância do marketing da Web3 e das mulheres na Web3: uma entrevista com Victoria Vaughan

Важность маркетинга Web3 и женщины в Web3: интервью с Викторией Вон

Web3 Pazarlamanın Önemi ve Web3'te Kadın: Victoria Vaughan ile Bir Röportaj

Tầm quan trọng của tiếp thị Web3 và phụ nữ trong Web3: Cuộc phỏng vấn với Victoria Vaughan

Web3 营销和 Web3 中的女性的重要性：维多利亚·沃恩 (Victoria Vaughan) 访谈

How the Binance Mothership Exerted Substantial Control Over its U.S. "Partner" from the Shadows  

কীভাবে বিন্যান্স মাদারশিপ ছায়া থেকে তার মার্কিন "অংশীদার" এর উপর যথেষ্ট নিয়ন্ত্রণ প্রয়োগ করেছে

Wie das Binance-Mutterschiff aus den Schatten heraus erhebliche Kontrolle über seinen US-amerikanischen „Partner“ ausübte

Cómo la nave nodriza de Binance ejerció un control sustancial sobre su "socio" estadounidense desde las sombras

Comment le vaisseau mère Binance a exercé un contrôle substantiel sur son « partenaire » américain depuis l'ombre

कैसे बिनेंस मदरशिप ने छाया से अपने अमेरिकी "साझेदार" पर पर्याप्त नियंत्रण स्थापित किया

バイナンスの母船はどのようにして米国の「パートナー」を影から実質的に支配したのか

바이낸스 모선이 그림자로부터 미국 "파트너"에 대해 실질적인 통제권을 행사한 방법

Como a nave-mãe Binance exerceu controle substancial sobre seu “parceiro” dos EUA nas sombras

Как Binance Mothership осуществляла существенный контроль над своим американским «партнером» из тени

Binance Mothership, ABD'li "Ortağı" Üzerinde Gölgelerden Nasıl Önemli Bir Kontrol Sağladı?

Làm thế nào Binance Mothership thực hiện quyền kiểm soát đáng kể đối với "Đối tác" Hoa Kỳ của mình từ trong bóng tối

币安母舰如何在暗处对美国“伙伴”实施实质性控制

FTC v. Binance Court Filing, retrieved on March 27, 2023, is part of . You can jump to any part in this filing . This is part 17 of 31. HackerNoon’s Legal PDF Series here V. FACTS I. Binance Has Directed Its VIP Customers to Evade Compliance Controls, Including Through Submission of “New” KYC Documents 123. In addition to instructing retail customers located in the United States to use VPNs to avoid IP address-based compliance controls, Binance has also created special policies and procedures to help its VIP customers evade Binance’s compliance controls so Binance could continue to access and derive profits from U.S. customers. Binance designed these special policies and procedures to help VIP customers evade both IP address-based compliance controls and KYC documentation-based compliance controls. 124. In February 2019, Lim and Zhao met in person to discuss how to address the regulatory risk stemming from Binance’s U.S. customers that access Binance via API. These customers are generally institutional market participants and include VIPs. In advance of their meeting, Lim sent Zhao a numbered list of “Compliance parameters,” including that “US API users (identified through IP) will have 2 options. They can remain on main exchange or move over to US exchange,” while “US API users (identified through KYC) have to move over to US exchange, they don’t have a choice. We will notify them through Email.” 125. Right after meeting with Lim, Zhao sent the compliance parameters to other senior managers, one of whom replied to Zhao that “[US users, with US, non international KYC] is [where] we will get nailed.” The senior manager asked Zhao if Binance had to “enforce” the contemplated block of US API users identified through KYC “in the matching engine? That’s the only way to guarantee this doesn’t break. [It] is not a hard thing to enforce in the matching engine.” Zhao replied: “let’s worry about enforcement in a later stage, think we may have to do it by users.” 126. On June 13, 2019, Binance released a press release that “announced its partnership with BAM Trading Services Inc. to begin preparation to launch trading services for users in the United States.” While outwardly preparing for the launch of Binance.US, internally, Zhao, Lim, and other key Binance personnel remained focused on retaining U.S. VIP customers, and the liquidity and revenue they supplied, on Binance. 127. In and around June 2019, Zhao, Lim, and other key Binance personnel engaged in a series of strategy sessions concerning the retention of U.S. VIPs on the Binance platform. One method discussed was to instruct U.S. VIP customers to submit “new” KYC documentation in connection with a “new” account. This approach would allow VIP customers to continue to trade on Binance and maintain their preferential VIP status and benefits that resulted from their historical trading activity on Binance. During one meeting that Binance recorded, a senior employee proposed that Binance instruct U.S. customers to submit “new” KYC documentation over social media—but Lim corrected the employee and mandated that such instructions should only occur in secret. 128. Binance’s plan to instruct U.S. VIP customers to submit “new” KYC documentation was devised by Zhao. During a June 24, 2019 meeting with senior management, Zhao stated: “We do need to let users know that they can change their KYC on Binance.com and continue to use it. But the message, the message needs to be finessed very carefully because whatever we send will be public. We cannot be held accountable for it.” In a meeting the next day, a senior VIP team member and Zhao engaged in the following colloquy: VIP team member: We don’t tell them explicitly because that’s marketing. But they [referring to U.S. VIP customers] understand . . . they know to send [their digital assets] the blockchain, then that’s their own control. And then so they send it to themselves, but we just help them expedite. As we speed up the account of the corporate account of the BVI or Cayman entity. Zhao: Okay, so is this them creating a new account, but we talked about having them change KYC has that ever been done? . . . . VIP team member: We quietly mentioned to them that, you know, US, you know, it could be an issue and you know, if they have any offshore entities, maybe they should open another one as well for their offshore entities. That’s how, that’s how we, that’s how we’ve been telling them. We haven’t really sent anything blasting because that’s, that’s sensitive. That’s marketing. I mean, [a U.S.-based compliance consultant] can comment on that. 129. Binance personnel began assisting U.S. VIP customers in creating “new” accounts using “new” KYC documentation as early as June 2019, and reported directly to Zhao on their efforts. For example, in a Binance group chat dated June 12, 2019, a Binance employee directed the following message to “@czhao,” which is a handle used by Zhao: Today our VIP team talked with three VIP8 users, we didn’t talk too much details and they all satisfied that we can help them onboarding their new non-US corporate accounts. That’s a good start, we’ll contact more VIPs tmr. Zhao responded in the same chat: “cool.” 130. At some point before October 2020, Binance formalized its processes for instructing U.S. VIP customers on the best methods to evade Binance’s compliance controls in a corporate policy titled “VIP Handling.” Zhao contributed ideas that were incorporated into the VIP Handling policy. Pursuant to the VIP Handling policy, once a customer service representative “hands the affected user over to VIP,” the VIP team would “[m]ake sure the user has completed his/her new account creation with no U.S. documents allowed.” U.S. VIP customers often followed these instructions by submitting “new” KYC documentation associated with a shell company incorporated in a jurisdiction other than the United States, such as the British Virgin Islands, to act as the nominee for the “new” account. 131. Acting pursuant to the VIP Handling policy, Binance’s VIP team would then “coordinate the transfer” of the VIP customer’s “Referral Bonuses, VIP level, Withdrawal Limits etc.” to the “new” account from the VIP customer’s pre-existing account. Thus, if the VIP team followed the VIP Handing policy correctly, from the customer’s perspective nothing about their trading on Binance would be disrupted—the “new” account would be the same as the old account with the exception of the name of the accountholder. 132. Recognizing the evasive nature of the procedures and strategies memorialized in the VIP Handling policy, the document required Binance employees to “[m]ake sure to inform user to keep this confidential.” In line with the intent to keep any “new account creations” by U.S. VIPs a secret, Zhao instructed during his October 13, 2020 “daily call” that any communications about the “US ban” should be done over the Signal messaging application. Thereafter, Lim circulated Zhao’s directive to a senior compliance staff member in a chat, explaining: “we do all U.S. comms via signal as mandated by cz.” 133. Binance’s VIP Handling policy also established methods for Binance personnel to troubleshoot for U.S. customers that were identified as such through their IP address (as opposed to KYC documentation). For these customers, Binance instructed its personnel to “[i]nform the user that the reason why he/she cant use our www.binance.com is because his/her IP is detected as US IP. If user doesn’t get the hint, indicate that IP is the sole reason why he/she can’t use .com” [emphasis in original]. 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 they figure it out on their own, its fine.” 134. Displaying the ecosystem’s tone at the top, Zhao helped manage the implementation of Binance’s VIP Handling policy. On October 9, 2020, around the time Binance began sending emails to U.S. customers pursuant to the policy, Zhao had the following exchange with an employee who would ultimately become Binance’s head of institutional sales: VIP team member: Hi CZ . . . I went through list of affected API clients, it includes a number of large strategic accounts including [a Chicago-headquartered trading firm] who is currently is a top 5 client and 12% of our volume Zhao: Give them a heads up to ensure they don’t connect from a us Ip. Don’t leave anything in writing. They have non us entities. Let’s also make sure we don’t hit the biggest market makers with that email first. Do you have signal? 135. At least until August 2021, over two years after Binance updated its Terms of Use to “restrict” U.S. customers, Binance employees continued to observe customers they had previously identified as U.S. VIPs trading on the platform. In an August 14, 2021 chat, members of the VIP and Compliance teams discussed the issue: Compliance employee: We have two corporate clients . . . which were detected as US nexus (US UBOs > 50%). Considering they are big clients, our compliance team wants to further check with you if we need to talk with the clients and give them a period before going offboard. Please advise. Thank you. VIP team member 1: we’ve gone through multiple offboarding exercises how is this coming up again? VIP team member 2: I guess because they’re a big client so there were delays here and there previously . . . there are still transactions going on during the month of august hahaha scary indeed. 136. Binance’s efforts to hold itself out as “compliant” while at the same time taking steps to assist customers in submitting “new” KYC documents has continued. For example, on August 5, 2021, Binance posted an announcement to Binance.com titled “Updates to API Services” that states: To ensure a safe and fair trading environment for all users and remain compliant with the latest industry requirements, Binance is updating its API services to limit new API key creation by accounts that have only completed basic account verification. This update is effective starting 2021-08-09 03:00 (UTC). For accounts that have not completed intermediate verification, any existing API keys will be changed to “read only” after 2021-08-23 00:00 AM (UTC). Trading functions via relevant API keys will be deactivated. Users can complete intermediate verification to reset API access and resume trading functions. But internal documents confirm that Binance was still up to its old tricks as of August 5, 2021. In a presentation concerning business operations that occurred during the week of August 9 through August 15, 2021, Binance personnel noted that they had made progress “Follow[ing] up [with high] value users KYC projuect [sic].” Continue Reading Here. About HackerNoon Legal PDF Series: We bring you the most important technical and insightful public domain court case filings. This court case 1:23-cv-01887 retrieved on September 4, 2023, from is part of the public domain. The court-created documents are works of the federal government, and under copyright law, are automatically placed in the public domain and may be shared without legal restriction. docdroid.net

FTC v. Binance: Binance Allegedly Directed Its VIP Customers to Evade Compliance

FTC v. Binance Court Filing, retrieved on March 27, 2023 is part of . You can jump to any part in this filing . This is part 14 of 31. HackerNoon’s Legal PDF Series here V. FACTS F. Binance’s Superficial Efforts to Limit Trading by United States Customers and Internal Recognition That Its Compliance Program Was Just “For Show” 89. Throughout the Relevant Period, Binance purposefully grew, maintained, and simultaneously concealed its U.S. customer base while also failing to implement an effective AML program that is required of financial institutions such as FCMs to detect and prevent terrorist financing or other criminal activity, among other things. One component of this failure to implement an effective AML program is Binance’s ongoing lack of effective KYC procedures or a CIP that would enable it to determine the true identity of its customers, whether from the United States or elsewhere. Further, as of at least May 2022, Binance had not filed a single suspicious activity report (“SAR”) in the United States despite having filed such reports in other jurisdictions. 90. For approximately the first two years of its operations, Binance did not take any steps to limit or restrict the ability of U.S. customers to trade on the platform. 91. Even after Binance began to purportedly restrict access to its platform from certain jurisdictions in mid-2019, it left open a loophole for customers to sign up, deposit assets, trade, and make withdrawals without submitting to any KYC procedures as long as the customer withdrew less than the value of two BTC in one day. Binance has referred to this two BTC-no KYC loophole by various labels, including “email registration,” and “tier 1” customers. The two BTC withdrawal limit was effectively meaningless—the notional value of two BTC in July 2019 was more than $22,000 and in March 2021 was more than $100,000. 92. Even before Binance made any attempts to restrict access to the platform by U.S. customers, Lim privately explained to Zhao that the two BTC-no KYC loophole would continue to allow U.S. customers to access the platform. In February 2019, Lim chatted to Zhao: “a huge number” of Binance’s “TIER 1 [meaning customers trading via the two BTC-no KYC loophole] could be U.S. citizens in reality. They have to get smarter and VPN through non-U.S. IP.” And Zhao stated during a management meeting in June 2019 that the “under 2 BTC users is [sic] a very large portion of our volume, so we don’t want to lose that,” although he also understood that due to “very clear precedents,” Binance’s policy of allowing “those two BTCs without KYC, this is definitely not possible in the United States.” 93. In June 2019, around the same time Binance announced a “partnership” with BAM Trading to launch what would become the Binance.US platform, Binance updated its Terms of Use to state for the first time that “Binance is unable to provide services to any U.S. person.” Binance also announced that “[a]fter 90 days, effective on 2019/09/12, users who are not in accordance with Binance’s Terms of Use will continue to have access to their wallets and funds, but will no longer be able to trade or deposit on Binance.com.” 94. In September 2019, Binance claimed it had begun to block customers based on their internet protocol (“IP”) address. 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. The pop-up did not block customers from logging in to their account, depositing assets, or trading on the platform, it just asked them to self-certify that they were not a U.S. person before accessing the platform by clicking a button on the pop-up. 95. Notwithstanding the pop-up compliance control, Binance knew that U.S. customers continued to comprise a substantial proportion of Binance’s customer base even after September 2019 because, among other reasons, Binance’s internal reporting told them so. According to periodic revenue reports prepared for and sent to Zhao every month, as of January 2020 approximately 19.9% of Binance’s customers were located in the United States, and as of June 2020—about a year after Binance amended its Terms of Use as alleged above in paragraph 93—approximately 17.8% of Binance’s customers were located in the United States. 96. In keeping with Binance and Zhao’s ethos of prioritizing profits over legal compliance, they knowingly allowed the two BTC-no KYC loophole to persist. In an October 2020 chat between Lim and a Binance colleague, Lim explained: [Because you attended a telephone conference on which Zhao participated] then you will also know that as a company, we are probably not going to remove no kyc (email registration) because its too painful . . . i think cz understands that there is risk in doing so, but I believe this is something which concerns our firm and its survivability. If Binance forces mandatory KYC, then [competing digital asset exchanges] will be VERY VERY happy. 97. Binance senior management, including Zhao, continued to be aware of and discuss the two BTC-no KYC loophole. For example, in a March 2021 Signal message group that included multiple senior managers, Zhao asked: “Who was in the 2BTC limit meeting last time?” 98. And on August 20, 2021, Binance announced that “all Binance users are required to verify their accounts,” meaning that all new customers would be required to complete “Intermediate Verification” and provide a government issued identification evidencing their geographic location. Binance also announced that existing customers that had not yet completed Intermediate Verification would have their account changed to “withdrawal only” status by October 19, 2021. Binance did not limit the ability of unverified customers to deposit funds and trade on the platform by October 19, 2021 as represented. In February 2022, Binance testified that the identities of approximately only 30–40% of its customers had been verified though KYC documentation. 99. Binance has been aware that its compliance controls have been ineffective. As Lim—at the time Binance’s CCO—recognized in an October 2020 chat with other Binance compliance personnel, Binance’s compliance environment has amounted to “email sending and no action . . . for media pickup . . . I guess you can say its ‘fo sho.’” 100. Zhao’s strategy of refusing to implement effective compliance controls at Binance was widely known within Binance. In a January 2019 chat between Lim and a senior member of the compliance team discussing their plan to “clean up” the presence of U.S. customers on Binance, Lim explained: “Cz doesn’t wanna do us kyc on .com.” And 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 “[n]o users will come.” 101. Despite their awareness of Binance’s compliance failures, Zhao, Lim, and others acting on behalf of Binance publicly represented that the platform had effective compliance controls. For example, in an August 14, 2019 letter sent on Binance letterhead, Lim assured a state financial regulator in the United States that [O]ur [compliance] program provides for AML/CFT controls to ensure the safe and legitimate use of our platforms . . . . Binance screens all its customers prior to the establishment of a business relations or undertaking a transaction against OFAC, EU, UK and Hong Kong sanctions . . . . Binance performs customer due diligence (CDD) anytime the company establishes a customer relationship with all customers engaged in crypto-fiat activity, where there is suspicion of money laundering or terrorism financing . . . . 102. Four months later, in an internal December 2019 message to a colleague, Lim admitted that “.com doesn’t even do AML namescreening/sanctions screening.” 103. Binance also intentionally tried to hide the scope of its compliance program’s ineffectiveness from its business partners. For example, in or around October 2020, Binance underwent a compliance audit to satisfy a request from Paxos. But according to Lim, Binance purposely engaged a compliance auditor that would “just do a half assed individual sub audit on geo[fencing]” to “buy us more time.” As part of this audit, the Binance employee who held the title of Money Laundering Reporting Officer (“MLRO”) lamented that she “need[ed] to write a fake annual MLRO report to Binance board of directors wtf.” Lim, who was aware that Binance did not have a board of directors, nevertheless assured her, “yea its fine I can get mgmt. to sign” off on the fake report. Around the same time as the referenced “half assed” compliance audit, in November 2020 the MLRO exclaimed to Lim in a chat, “I HAZ NO CONFIDENCE IN OUR GEOFENCING.” 104. Internally, Binance officers, employees, and agents have acknowledged that the Binance platform has facilitated potentially illegal activities. For example, in February 2019, after receiving information “regarding HAMAS transactions” on Binance, Lim explained to a colleague that terrorists usually send “small sums” as “large sums constitute money laundering.” Lim’s colleague replied: “can barely buy an AK47 with 600 bucks.” And with regard to certain Binance customers, including customers from Russia, Lim acknowledged in a February 2020 chat: “Like come on. They are here for crime.” Binance’s MLRO agreed that “we see the bad, but we close 2 eyes.” 105. Lim’s internal discussions with compliance colleagues illustrate that Binance has tolerated Binance customers’ use of the platform to facilitate “illicit activity.” For example, in July 2020, a Binance employee wrote to Lim and another colleague asking if a customer whose recent transactions “were very closely associated with illicit activity” and “over 5m USD worth of his transactions were indirectly sourced from questionable services” should be off-boarded or if it was in the class of cases “where we would want to advise the user that they can make a new account.” Lim chatted in response: Can let him know to be careful with his flow of funds, especially from darknet like hydra He can come back with a new account But this current one has to go, it’s tainted 106. Lim’s instruction to allow a customer “very closely associated with illicit activity” to open a new account and continue trading on the platform is consistent with Zhao’s business strategy, which has counseled against off-boarding customers even if they presented regulatory risk. For example, in a September 2020 chat Lim explained to Binance employees that they Don’t need to be so strict. Offboarding = bad in cz’s eyes. 107. Binance’s corporate communications strategy has attempted to publicly portray that Binance has not targeted the United States at the same time Binance executives acknowledge behind closed doors that the opposite is true. For example, on June 9, 2019, around the time Zhao and Binance hatched their secret plot to retain U.S. customers even after the launch of Binance.US, Binance’s Chief Financial Officer stated during a meeting with senior management including Zhao: [S]ort of, the messaging, I think would develop it as we go along is rather than saying we’re blocking the US, is that we’re preparing to launch Binance US. So, we would never admit it publicly or privately anywhere that we serve US customers in the first place because we don’t. So, it just so happens we have a website and people sign up and we have no control over [access by U.S. customers] . . . . [B]ut we will never admit that we openly serve US clients. That’s why the PR messaging piece is very, very critical Zhao agreed that Binance’s “PR messaging” was critical, explaining in a meeting the next day that “we need to, we need to finesse the message a little bit . . . . And the message is never about Binance blocking US users, because our public stance is we never had any US users. So, we never targeted the US. We never had US users.” But during the June 9, 2019 meeting, Zhao himself stated that “20% to 30% of our traffic comes from the US,” and Binance’s “July [2019 Financial] Reporting Package,” which was emailed directly to Zhao, attributes approximately 22% of Binance’s revenue for June 2019 to U.S. customers. Continue Reading . Here About HackerNoon Legal PDF Series: We bring you the most important technical and insightful public domain court case filings. This court case 1:23-cv-01887 retrieved on September 4, 2023, from is part of the public domain. The court-created documents are works of the federal government, and under copyright law, are automatically placed in the public domain and may be shared without legal restriction. docdroid.net

FTC v. Binance: Was Binance's Compliance Program Just For Show?

The Worms of Purgatory: When the Hunter Becomes the Hunted

The Worms of Purgatory: যখন শিকারী শিকারে পরিণত হয়

Die Würmer des Fegefeuers: Wenn der Jäger zum Gejagten wird

Los gusanos del purgatorio: cuando el cazador se convierte en cazado

Les Vers du Purgatoire : Quand le chasseur devient le chassé

यातना के कीड़े: जब शिकारी शिकार बन जाता है

煉獄の虫：狩る者が狩られる時

연옥의 벌레: 사냥꾼이 사냥당할 때

Os vermes do purgatório: quando o caçador se torna caçado

Araf Solucanları: Avcı Av Olduğunda

Những con sâu luyện ngục: Khi thợ săn trở thành kẻ bị săn

炼狱之虫：当猎人成为猎物

Requesting and receiving data from internet sources is one of the basics of programming but isn’t taught  by most ‘Learn to Code <Programming Language>’ courses. For self-taught programmers, this is one of the skills that will get you moving further along your learning journey and make you better than 90% of the others. What is an API? Short for Application Programming Interface, API helps a program fetch information from various internet sources. Let’s say you’re building a basic currency conversion program in python. It takes an input amount of currency X and converts it into currency Y Sample Code for reference: def currency_converter ():

    currency_a = input ("Enter the currency you want to convert: ")

    currency_b = input ("Enter the currency you want to convert to: ")

    amount = float (input ("Enter the amount you want to convert: "))

    exchange_rate = float (input ("Enter the exchange rate: "))

    print(f"{amount} {currency_a} is equal to \
        {amount * exchange_rate} {currency_b}")
    
currency_converter () This program in its current form is no more than a glorified calculator - not of much use as a program. This is where APIs come in!! With a few lines of code, this program can be made so powerful that it does not need to ask for the exchange rate. Instead, with APIs, the code would be able to fetch the current exchange rate and provide it to the program. Need to make a program to give the country code for an input country? There’s an API for that. Inventory in your warehouse? Data in your spreadsheet? Payment confirmation? Email notification? All done with APIs! To put it simply, APIs enable communications between computing devices in a standardized manner. For example, if you go to Germany and use an interpreter to help translate for you, the interpreter is the API. Components of an API . An API has 3 elements - Request, Response, and Resource Request - You asking the interpreter to say ‘Good Day’ to a German is the request Response - What the German said back is the response Resource - The data within the response (‘Guten Tag’) is the resource In our program above, let’s see what the API needs to do: """

Request -- Our program requests for the currency_a -> currency_b exchange rate

Response -- API endpoint reads our request, fetches that information, and responds back

Resource -- The exchange rate data sent back is the resource

""" API Endpoint? What’s that? As we know by now (as self-taught programmers) that computers need very precise inputs in a very precise manner. Any deviation or any expectation from the computer to ‘understand things as we do’ is just going to lead to chaos! In that vein, we must understand that even API requests need to be structured in a very precise way. This is what the general structure of an API looks like: -- This is the URL that receives the API Endpoint Request. -- This is the type of API request and is of several types such as: Method GET -- indicates that the request is looking to fetch info from the server. POST -- indicates that the request is looking to send some info to a server. DELETE -- indicates that the request is looking to delete some info from the server. PUT/PATCH -- indicates that the request is looking to update existing info on the server. -- This provides some context about the Requested. Header Resource -- This is the main part of the request that triggers the Body Response. CRUD Responses CRUD stands for Create, Read, Update, and Delete and is performed by using the relevant API method in the API Request: API Method Response Description GET Read fetches existing info from the server POST Create adds info to the server DELETE Delete deletes info on the server PUT/PATCH Update updates info on the server Fetching Realtime Currency Rates into our Program Now we’re sufficiently ready to fetch the real-time currency rates into our sample program given earlier. We’ll be using the requests module for this exercise which you can get via pip3 install requests in your code editor’s (like VSCode) terminal. APIs that provide data come in Free and Paid forms - depending on the ease of use. I found a free source and shall be using it because it does not force me to sign up as long as I’m just testing here. ExchangeRateAPI API data usually comes in the form of a JSON (very similar to a dictionary in python) for easy interpretation by the programmers fetching that data. Here’s the code for fetching the current price of the US Dollar via the API. import requests
url =  "https://open.er-api.com/v6/latest/USD"
r = requests.get(url)
data = r.json()
print (data) Running this code will output the following: {'result': 'success', 
'provider': 'https://www.exchangerate-api.com', 
'documentation': 'https://www.exchangerate-api.com/docs/free', 
'terms_of_use': 'https://www.exchangerate-api.com/terms', 
'time_last_update_unix': 1666828952, 
'time_last_update_utc': 'Thu, 27 Oct 2022 00:02:32 +0000', 
'time_next_update_unix': 1666916222, 
'time_next_update_utc': 'Fri, 28 Oct 2022 00:17:02 +0000', 
'time_eol_unix': 0, 
'base_code': 'USD', 
'rates': {'USD': 1, 'AED': 3.6725, 'AFN': 87.825832, 'ALL': 118.121569, 
'AMD': 400.945057, 'ANG': 1.79, 'AOA': 469.341287, 'ARS': 155.541325, 'AUD': 1.541873,
 'AWG': 1.79, 'AZN': 1.703727, 'BAM': 1.945846, 'BBD': 2, 'BDT': 101.652423, 
'BGN': 1.946569, 'BHD': 0.376, 'BIF': 2061.89311, 'BMD': 1, 'BND': 1.40599, 
'BOB': 6.931975, 'BRL': 5.314395, 'BSD': 1, 'BTN': 81.988812, 'BWP': 13.376498, 
'BYN': 2.887549, 'BZD': 2, 'CAD': 1.355432, 'CDF': 2080.191892, 'CHF': 0.986916, 
'CLP': 967.707002, 'CNY': 7.181598, 'COP': 4992.818412, 'CRC': 624.374829, 'CUP': 24, 
'CVE': 109.702113, 'CZK': 24.428037, 'DJF': 177.721, 'DKK': 7.422296, 'DOP': 53.948303,
 'DZD': 140.691654, 'EGP': 19.734057, 'ERN': 15, 'ETB': 53.10939, 'EUR': 0.994984, 
'FJD': 2.280573, 'FKP': 0.862476, 'FOK': 7.422296, 'GBP': 0.862495, 'GEL': 2.780813, 
'GGP': 0.862476, 'GHS': 14.477856, 'GIP': 0.862476, 'GMD': 60.196663, 
'GNF': 8658.722933, 'GTQ': 7.851475, 'GYD': 210.222337, 'HKD': 7.848858, 
'HNL': 24.756699, 'HRK': 7.496037, 'HTG': 127.760311, 'HUF': 407.402111, 
'IDR': 15518.182729, 'ILS': 3.502567, 'IMP': 0.862476, 'INR': 81.991335, 
'IQD': 1466.589463, 'IRR': 42121.422024, 'ISK': 142.934149, 'JEP': 0.862476, 
'JMD': 153.171604, 'JOD': 0.709, 'JPY': 146.478104, 'KES': 121.814832, 
'KGS': 83.278965, 'KHR': 4159.804229, 'KID': 1.541816, 'KMF': 489.456326, 
'KRW': 1414.443423, 'KWD': 0.29963, 'KYD': 0.833333, 'KZT': 470.670656, 
'LAK': 17297.850805, 'LBP': 1507.5, 'LKR': 362.205766, 'LRD': 154.022883, 
'LSL': 17.964161, 'LYD': 5.043916, 'MAD': 10.860577, 'MDL': 19.373927, 
'MGA': 4262.390442, 'MKD': 61.999441, 'MMK': 2425.598271, 'MNT': 3414.010756, 
'MOP': 8.084315, 'MRU': 38.145372, 'MUR': 43.95057, 'MVR': 15.474793, 
'MWK': 1033.698319, 'MXN': 19.911183, 'MYR': 4.709804, 'MZN': 64.481751, 
'NAD': 17.964161, 'NGN': 437.991325, 'NIO': 36.062907, 'NOK': 10.27411, 
'NPR': 131.1821, 'NZD': 1.717982, 'OMR': 0.384497, 'PAB': 1, 'PEN': 3.994793, 
'PGK': 3.535979, 'PHP': 58.319524, 'PKR': 220.984121, 'PLN': 4.728217, 
'PYG': 7249.701869, 'QAR': 3.64, 'RON': 4.844272, 'RSD': 116.906933, 
'RUB': 61.346183, 'RWF': 1075.383068, 'SAR': 3.75, 'SBD': 8.07199, 'SCR': 13.126076, 
'SDG': 572.688874, 'SEK': 10.875131, 'SGD': 1.405948, 'SHP': 0.862476, 
'SLE': 17.636956, 'SLL': 17636.95595, 'SOS': 571.245973, 'SRD': 29.467417, 
'SSP': 611.916602, 'STN': 24.374931, 'SYP': 2514.92413, 'SZL': 17.964161, 
'THB': 37.747911, 'TJS': 10.200292, 'TMT': 3.504191, 'TND': 3.085688, 
'TOP': 2.388017, 'TRY': 18.607129, 'TTD': 6.77608, 'TVD': 1.541816, 
'TWD': 32.049926, 'TZS': 2335.14976, 'UAH': 37.234725, 'UGX': 3826.845217, 
'UYU': 41.283595, 'UZS': 11139.838897, 'VES': 8.4508, 'VND': 24821.263771, 
'VUV': 122.039898, 'WST': 2.787278, 'XAF': 652.608434, 'XCD': 2.7, 'XDR': 0.774448, 
'XOF': 652.608434, 'XPF': 118.722827, 'YER': 251.106608, 'ZAR': 17.964381, 
'ZMW': 16.127703, 'ZWL': 644.87339}} Looking at this JSON (Imma call it a dictionary from hereon for pythonic reasons), we see that the currency rates against that of the USD as base currency are given in the internal dictionary which can be accessed with the key. rates The actual conversion rate to a particular currency can be accessed by using the desired currency’s 3-letter currency code. For example, to get the conversion rate to INR (Indian Rupee), I will first need to use the key and then the key within the key. rates INR rates Case-sensitivity is important in most APIs so we’ll need to plan for that in our code as well. The code to get the USD to INR conversion rate, the code in python would look like this - inr_rate = data['rates'].get('INR', 'Not Found') Let’s now update our original code to become less of a calculator and more of a computer: import requests

def currency_converter ():
    currency_a = input ("Enter the currency you want to convert: ")
    currency_a = currency_a.upper() 
    #accepts user input for base currency name and converts it to uppercase
    
    currency_b = input ("Enter the currency you want to convert to: ")
    currency_b = currency_b.upper() 
    #accepts user input for final currency name and converts it to uppercase
    
    currency_converter_api = "https://open.er-api.com/v6/latest/" + currency_a
    #makes currency_a the base currency
    
    api_response = requests.get(currency_converter_api)
    #fetches the api response - the R from CRUD
    
    api_response_json = api_response.json()
    #Converts the response object into a JSON object
    
    amount_to_convert = float (input (f"Enter the amount of {currency_a} \
      you want to convert to {currency_b}: "))
    #accepts user input for the amount to convert as a float
    
    try:
        exchange_rate = api_response_json['rates'].get(currency_b, \
          'Currency Not Supported by API')

        if exchange_rate == 'Currency Not Supported by API':

            print ("Final Currency Not Supported by API")

        else:

            converted_amount = amount_to_convert * exchange_rate

            print (f"{amount_to_convert} {currency_a} is \
              equal to {converted_amount} {currency_b}")
    
    except KeyError:
        print ("Base Currency Not Supported by API")
    # for catching errors is the base currency name is not supported by the API
    
currency_converter () There you go - now it does a little better: Converting 5000 INR to EUR (successful conversion calculation): """
Enter the currency you want to convert: inr
Enter the currency you want to convert to: eur
Enter the amount of INR you want to convert to EUR: 5000
5000.0 INR is equal to 60.72 EUR
""" Converting unsupported currency (error-handling): """
Enter the currency you want to convert: utsav
Enter the currency you want to convert to: inr
Enter the amount of UTSAV you want to convert to INR: 45
Base Currency Not Supported by API
""" Converting TO Unsupported currency (error-handling): """
Enter the currency you want to convert: inr
Enter the currency you want to convert to: utsav
Enter the amount of INR you want to convert to UTSAV: 89
Final Currency Not Supported by API
""" Some Final Notes: While we've used print statements here for illustrative reasons, if you’re building an app, avoid print statements and use return instead Some premium APIs (paid) offer better sources, the ability to take full-name inputs (Indian Rupee) or just country as input (USA) and respond with the desired response Most APIs require the use of API keys for authentication and DDoS prevention features. Read more about them . here Resource Attributions: RapidAPI #API on HackerNoon Recommended Readings: Low Code APIs Error-Handling in React APIs Using Google Sheets API in Python Securing your API data GraphQL API

API for Beginners: Requests, Responses, Resources, and GET Explained with Code

Song of the Cicada Project and the Mystery of Cicada 3301

SEC v. Binance Court Filing, retrieved on June 5, 2023 is part of . You can jump to any part in this filing . This is part 67 of 69. HackerNoon’s Legal PDF Series here FACTS IX. BINANCE AND BAM TRADING WERE REQUIRED TO BUT DID NOT REGISTER AS AN EXCHANGE, BROKER-DEALER, OR CLEARING AGENCY. THIRTEENTH CLAIM FOR RELIEF Violations of Securities Act Sections 17(a)(2) and (a)(3) (Against BAM Management and BAM Trading) 554. The Commission realleges and incorporates by reference herein the allegations in Paragraphs 1-35, 110-324, and 352-513 555. At all relevant times, by engaging in the conduct alleged in this Complaint, specifically by making materially false and misleading statements to investors and engaging in acts and practices that operated as a fraud upon purchasers, BAM Management and BAM Trading have, in the offer or sale of securities by the use of the means and instruments of transportation or communication in interstate commerce or by use of the mails, directly or indirectly, obtained money or property by means of one or more untrue statements of a material fact or omissions of a material fact necessary to make the statements made, in light of the circumstances under which they were made, not misleading, and engaged in one or more transactions, practices, or courses of business which operated or would operate as a fraud or deceit upon the purchaser. 556. By reasons of the foregoing, BAM Management and BAM Trading, directly or indirectly, singly or in concert, have violated, and unless enjoined will again violate, Securities Act Section 17(a)(2)-(3) [15 U.S.C. § 77q(a)(2) and 77q(a)(3)]. Continue Reading . Here About HackerNoon Legal PDF Series: We bring you the most important technical and insightful public domain court case filings. This court case 1:23-cv-01599 retrieved on September 6, 2023, from is part of the public domain. The court-created documents are works of the federal government, and under copyright law, are automatically placed in the public domain and may be shared without legal restriction. docdroid.net

BAM Management and BAM Trading Charged for "Making Materially False Statements and Omissions"

BAM COMMUNICATIONS

bamcommunications.biz

-- employees

Since n.d.

COMPANY RANKING

BAM COMMUNICATIONS

EVERGREEN INDEX #1790

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BAM COMMUNICATIONS

bamcommunications.biz

-- employees

Since n.d.

COMPANY RANKING

BAM COMMUNICATIONS

EVERGREEN INDEX #1790

RELATED COMPANIESRANK

STORIES ABOUT BAM COMMUNICATIONS

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