White Collar & Government Investigations Blog

Co-Chair of Olshan’s White Collar & Government Investigations Practice Robert Appleton was prominently quoted in a breaking Fortune article on the Binance cryptocurrency sanctions scandal entitled “Inside the Binance Accounts Internal Investigators Say Helped Transfer More Than $1 Billion to Iran-Linked Entities: A 79-Year-Old VIP Chinese Trader and a Suspected Iranian Gold Smuggler.” The article exposes crypto flows from Binance accounts to a cluster of wallets investigators linked to Iran-connected sanctioned entities and ultimately to sanctioned groups, following the conviction of both the exchange and its CEO in US District Court last year for permitting transactions over its exchange for the benefit of the Iranian regime and sanctioned entities. The article highlights the suspicious transactions occurring over the exchange, the firing of internal investigators and the timing of these events. Bob provides significant quotes on the central issue of the piece and the compliance requirements at issue. Bob explains how a company under a monitorship and following a plea agreement needs to be extra vigilant on monitoring transactions on its platform as compliance expectations change when a company enters into a plea agreement with the government and is effectively on probation. In such circumstance, Bob explains that suspicious activity should be treated with heightened urgency as part of a more rigorous sanctions and anti-money laundering (AML) posture. As a recognized former federal prosecutor in the DOJ who handled numerous high profile Iran-related sanctions cases and is well known as a sanctions expert, Bob explained that because of Binance’s prior plea agreement with the government for admitting to the same prohibited conduct, he expected the exchange would be more vigilant about suspicious activity of any sort: “That agreement with the government changes everything because it increases their obligations.”