The first goal, enforcement mitigation, is designed to minimize the impact of U.S. regulation. It explicitly mentions the need to undermine the ability of “anti-money laundering and U.S. sanctions enforcement” to detect illicit activity. More specifically, it describes a detailed strategy for distracting the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC), the Securities and Exchange Commission (SEC), the Commodity Futures Trading Commission (CFTC), and the New York Department of Financial Services (NYDFS).
Notably, the document explicitly calls for the “strategic” use of virtual private networks (VPNs) that obscure traders’ locations as a way to evade regulatory scrutiny by the SEC and the NYDFS. In addition to a guide to using VPN’s on Binance’s website, CZ has in multiple instances advocated for VPN use as a way to obscure a user’s location. In a June 2019 tweet he wrote that VPNs are “a necessity, not optional.”
Days before Binance officially launched in July 2017, the exchange raised about $15 million by selling BNB, which could in turn be used to pay fees, and was given away as an incentive for recommending new Binance traders. Binance’s novel approach, which is somewhat reminiscent of Amway-style multi-level marketing organizations, has created loyalty among its customers, and solved the nagging problems of retention experienced by many exchanges. The digital currency, whose float the company actively controls, is now worth $4.4 billion.
[Forbes] Leaked document shows Binance actively undermining U.S. Regulators & Law Enforcement Agencies
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