Unchained

How Binance Will Open All Its Activity to the U.S. Government - Ep. 581

Dec 12, 2023
Michael Dawson, a partner at WilmerHale specializing in financial compliance, and Dorothy DeWitt, founder of Tolt Strategies and former CFTC director, dive into Binance's recent $4.3 billion settlement with the U.S. government. They discuss the role of compliance monitors, why they were deemed necessary, and how this impacts the broader crypto landscape. The pair also explore challenges faced by Binance in complying with U.S. regulations and the potential ripple effect of increased monitorships across the industry.
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INSIGHT

FinCEN's First Monitor

  • This marks the first time FinCEN has included a compliance monitor in a settlement.
  • It also involves their largest fine ever, indicating the significance of this case.
ADVICE

Binance's Monitor Selection Priorities

  • Binance should prioritize cost-effectiveness, appropriate scope, and early monitorship termination possibilities.
  • The "look back" is crucial, examining past transactions for suspicious activity.
ANECDOTE

Potential Monitor Candidate

  • Dorothy DeWitt mentions her experience as CFTC director, Coinbase general counsel, and Senate legislative drafter.
  • She positions herself as a potential candidate for the monitorship, highlighting her diverse experience.
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