Key Entities in the SEC v. Binance Saga: Trust Companies, Sigma Chain, and Merit Peak

CERTAIN OTHER ENTITIES

31. Trust Company A is a New York limited purpose trust company. Beginning in September 2019, pursuant to a “Stablecoin as a Service” agreement with a Binance affiliate, Trust Company A issued in partnership with Binance the crypto asset “BUSD,” which was approved by and under the supervision of the New York Department of Financial Services (“NYDFS”). BUSD is a Binance-branded U.S. Dollar denominated crypto asset on the Ethereum blockchain. In December 2019, BAM Trading entered into a partnership with Trust Company A, whereby Trust Company A provided certain services with respect to BUSD purchases and sales on the Binance.US Platform. Effective February 21, 2023, Trust Company A ceased issuing new BUSD pursuant to an NYDFS order.

32. Trust Company B is a Nevada-based trust company. In or around July 2019, BAM Trading entered into an agreement with Trust Company B to provide certain services to customers purchasing crypto assets on the Binance.US Platform with U.S. dollars.

33. Sigma Chain is a crypto asset trading firm incorporated in Switzerland. Zhao is Sigma Chain’s beneficial owner, and several Binance employees conducted its operations. Among others, Binance’s back office manager (“Binance Back Office Manager”) was Sigma Chain’s President at the same time she also had signatory authority over BAM Trading’s bank accounts. Sigma Chain was an active trader on both Binance Platforms, and described itself as “the main market maker for Binance.com.” Upon the Binance.US Platform’s launch, Zhao directed that Sigma Chain be one of its first market makers. Further, since the Binance.US Platform began offering over-the-counter (“OTC”) trading and its Convert Trading and One Click Buy Sell (“OCBS”) Services to customers, Sigma Chain has served as one of the counterparties to Binance.US Platform customers, including, at times, serving as the only counterparty.

34. Merit Peak Limited (“Merit Peak”) is a crypto asset trading firm incorporated in the British Virgin Islands. Zhao is Merit Peak’s beneficial owner, and several Binance employees conducted its operations. It has described itself as “a proprietary firm trading with our owner’s [Zhao’s] self-made wealth from the digital asset business.” Merit Peak was an OTC trading service provider on the Binance.com Platform and was one of the earliest market makers on the Binance.US Platform. Through Merit Peak, Zhao has also directed over $16 million to BAM Management to fund the Binance.US Platform’s operations.

35. Below is a high-level graphical representation of a certain limited number of relationships and entities relevant to the allegations herein.