The Justice Department is reviewing Binance’s compliance with its 2023 settlement. Officials have not said that Binance breached the agreement. Prosecutors are examining transactions that may
The U.S. Department of Justice is reviewing whether Binance has honored the plea agreement it signed in November 2023, a deal that cost the exchange $4.3 billion. Tysen Duva, who leads the department’s Criminal Division, confirmed the review on October 9 without disclosing findings, and he did not say the company had broken the agreement. Prosecutors in Manhattan and Washington want to know whether Binance knowingly allowed transactions that breach U.S. sanctions on Iran and whether its internal controls meet the standard the settlement set.
The review follows a civil forfeiture complaint that the Southern District of New York filed in September, seeking roughly $61 million in cryptocurrency tied to black-market Iranian oil sales. Prosecutors allege that two Chinese companies, Blessed Trust and Hexa Whale, used Binance accounts to process proceeds from sanctioned crude, as part of a wider network that laundered more than $1.5 billion for Iranian government entities including the Islamic Revolutionary Guard Corps. The complaint does not claim that Binance or its employees knowingly took part.
A U.S. newspaper investigation published on October 9 traced about $850 million through 21 Binance accounts associated with Iranian financier Babak Zanjani, accounts the exchange says it finished removing in May 2026. A February report said Binance’s own investigators had flagged more than $1 billion in USDT transfers to entities possibly linked to Iran, and that at least five of them left the company from late 2025 onward. Binance denies dismissing anyone for raising concerns.
A sanctions investigation asks whether prohibited transactions took place. A settlement review asks something narrower: whether the company did what it promised in exchange for closing the 2023 case. Binance pleaded guilty then to anti-money-laundering failures, unlicensed money transmission and sanctions violations. Iran was already central, with prosecutors citing more than $898 million in trades between U.S. users and users resident in Iran from 2018 to 2022.
In return, Binance accepted a three-year independent monitor under the DOJ resolution, five years of sanctions compliance monitoring under its agreement with OFAC, the Treasury office that enforces sanctions, and a duty to report evidence or allegations of misconduct. That reporting duty is where the recent allegations bite. If staff flagged Iran-linked flows and the company failed to act on them or pass them to the authorities, prosecutors would be looking at a breach of plea terms, which can revive charges the settlement had closed. Knowledge is the hard part to prove, because suspicious money passing through a platform of this size does not by itself show the company knew. Founder Changpeng Zhao’s October 2025 pardon does not lift the company’s obligations.
The exchange set out its defense in a statement on March 10. By its own, unverified count, sanctions-related exposure as a share of trading volume fell 96.8% between January 2024 and July 2025, and it spends more than $200 million a year on compliance, a function that employs a fifth of its staff. Binance also argues that much of the volume described in press reports had no confirmed Iranian connection.
No new violation has been established. Prosecutors could close the review without action, or they could require remediation and tighter monitoring. New penalties or criminal proceedings would follow only if they establish fresh offenses or a material breach, and OFAC’s 2023 settlement explicitly reserved the right to seek additional penalties in that case.
Earlier OFAC cases against crypto platforms ended with a single payment. Kraken settled for $362,159 in 2022 over services to users apparently located in Iran. Binance is the first large exchange to have its conduct examined after accepting a monitor, so the way prosecutors treat its internal escalation records will matter to any platform under a similar agreement.
Congress is running a parallel track. Senator Richard Blumenthal opened an inquiry in February, and in July Senator Adam Schiff and other lawmakers raised the Zanjani-linked transfers. Those inquiries carry no finding of wrongdoing.
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