The United States Department of Justice is scrutinizing whether Binance Holdings breached its $4.3 billion 2023 settlement agreement, reviewing platform activity for potential Iran sanctions violations while prosecutors examine post-settlement compliance controls and transaction flows involving Hong Kong entities.
The United States Department of Justice has opened an active review into whether Binance Holdings Ltd. has adhered to the terms of its landmark late-2023 plea agreement, centering on whether the world’s largest cryptocurrency exchange permitted transactions that breached sanctions against Iran. Tysen Duva, head of the DOJ’s criminal division, confirmed the review during an interview, noting that officials are actively assessing the exchange’s adherence to the multi-billion-dollar settlement.
While the department has not formally accused the platform of violating the accord, prosecutors in Washington and New York are examining how the exchange’s compliance machinery operated after the initial case resolved.
Investigators Examine Zedcex Account Access from Tehran
The central question for investigators is not what happened before the 2023 resolution, but whether Binance’s internal controls failed afterward. Prosecutors have been examining a high-value corporate customer named Zedcex that maintained a special status and a custom interface on the platform. Binance’s internal investigation found that this account was accessed from Tehran on more than a dozen occasions between late 2024 and late 2025.
The timeline of that account forms a core piece of the ongoing review.
Binance Paid $4.3 Billion Penalty in 2023
The current scrutiny arrives against the backdrop of one of the largest corporate penalties in digital asset history. In November 2023, Binance pleaded guilty to violating the Bank Secrecy Act, operating an unlicensed money-transmitting business, and sanctions-related offenses. The total financial penalty exceeded $4.3 billion.
Founder Changpeng Zhao pleaded guilty separately to failing to maintain an effective anti-money-laundering program, paid a $50 million fine, and served a four-month prison sentence. As part of the 2023 agreement, Binance accepted a multi-year monitorship. Forensic Risk Alliance took on a three-year assignment, while Sullivan & Cromwell assumed a five-year mandate.
Binance Offboards Suspicious Accounts to Show Compliance
Binance has maintained that it operates with a zero-tolerance policy toward sanctions violations and emphasized its ongoing cooperation with law enforcement. To demonstrate its compliance efforts, the exchange pointed to its proactive offboarding of suspicious accounts, noting that it removed such entities in August 2025 and again in January 2026.
“We continue to strengthen our control framework and remain fully committed to cooperating with law enforcement.”
Binance representative
At the same time, senior Justice Department officials have emphasized a broader strategy of encouraging digital asset companies to self-report potential misconduct. Tysen Duva praised crypto exchanges for assisting authorities in disrupting transnational cyber scams and financial fraud, noting that proactive disclosures can lead to settlements rather than prolonged prosecutions.
“The early returns have been great with social media, with crypto exchanges, and we’re very excited to really press that and continue this. A big part of this is these public-private partnerships.”
Tysen Duva, head of DOJ’s criminal division
Under the terms of its settlement, Binance is explicitly required to report any evidence or allegations of misconduct involving money laundering, banking transactions, or sanctions violations to the U.S. government. Whether the current compliance review concludes quietly or results in formal allegations depends on whether prosecutors establish that the exchange knowingly allowed prohibited transactions to proceed after the 2023 agreement was signed.