On November 21, 2023, the Cayman Islands registered cryptocurrency exchange, Binance Holdings Limited (the “Company”), pled guilty to criminal violations related to allegedly failing to register as a money transmitting business (“MTB”), failing to maintain an effective anti-money laundering program, and violations of the International Emergency Economic Powers Act (“IEEPA”).  In connection with its plea agreement with the Department of Justice, the Company agreed to pay $4.3 billion in penalty, including $1.8 billion as a criminal fine and $2.5 billion in disgorgement.  The Company’s founder also pled guilty to similar AML violations and agreed to resign as the Company’s Chief Executive Officer.

On April 21, 2022, the Office of the Comptroller of the Currency (OCC) issued a consent order against Anchorage Digital Bank, a digital asset bank based in South Dakota.  Notably, Anchorage had previously become the first digital asset bank to be regulated by the OCC in January 2021.  In its consent order, the OCC determined that Anchorage had failed to adopt an effective compliance system as required by the Bank Secrecy Act and anti-money-laundering (“AML”) laws, specifically highlighting failures related to “internal controls for customer due diligence and procedures for monitoring suspicious activity, BSA officer and staff, and training.”