FTC v. Binance: The Other Relevant Entities You Should Know About

III. PARTIES

C. Other Relevant Entities

19. Binance UAB is incorporated in Lithuania and directly or indirectly owned by Zhao. Binance UAB is the only entity specifically identified as one of the indeterminate group of “Binance Operators” referenced in Binance’s Terms of Use. Binance UAB has never been registered with the Commission in any capacity.

20. Merit Peak Limited (“Merit Peak”) is incorporated in the Cayman Islands and directly or indirectly owned by Zhao. Merit Peak has primarily engaged in over the counter (“OTC”) transactions with institutional counterparties. Merit Peak has never been registered with the Commission in any capacity.

21. Sigma Chain AG (“Sigma Chain”) is incorporated in Switzerland and directly or indirectly owned by Zhao. It has engaged in proprietary trading in Binance’s various markets, including its markets for digital asset derivatives. Sigma Chain has never been registered with the Commission in any capacity.

22. BAM Trading Services Inc. (“BAM Trading”) is a Delaware company with its principal address in Palo Alto, California. BAM Trading operates Binance.US, a spot digital asset trading platform that offers its services to U.S. residents and relies on Binance’s services and technology, obtained through intercompany agreements, to operate.

BAM Trading is directly or indirectly majority owned and controlled by Zhao, and Zhao has been a director of BAM Trading at all relevant times. BAM Trading has never been registered with the Commission in any capacity.