Bitcoin - trading och analys

Internally, Binance officers, employees, and agents have acknowledged that the
Binance platform has facilitated potentially illegal activities. For example, in February 2019,
after receiving information “regarding HAMAS transactions” on Binance, Lim explained to a
colleague that terrorists usually send “small sums” as “large sums constitute money laundering.”
Lim’s colleague replied: “can barely buy an AK47 with 600 bucks.” And with regard to certain
Binance customers, including customers from Russia, Lim acknowledged in a February 2020
chat: “Like come on. They are here for crime.” Binance’s MLRO agreed that “we see the bad,
but we close 2 eyes.”

Lim’s internal discussions with compliance colleagues illustrate that Binance has
tolerated Binance customers’ use of the platform to facilitate “illicit activity.” For example, in
July 2020, a Binance employee wrote to Lim and another colleague asking if a customer whose
recent transactions “were very closely associated with illicit activity” and “over 5m USD worth
of his transactions were indirectly sourced from questionable services” should be off-boarded or
if it was in the class of cases “where we would want to advise the user that they can make a new
account.” Lim chatted in response:
Can let him know to be careful with his flow of funds, especially from darknet
like hydra
He can come back with a new account
But this current one has to go, it’s tainted

Lim’s instruction to allow a customer “very closely associated with illicit
activity” to open a new account and continue trading on the platform is consistent with Zhao’s
business strategy, which has counseled against off-boarding customers even if they presented
regulatory risk. For example, in a September 2020 chat Lim explained to Binance employees
that they
Don’t need to be so strict.
Offboarding = bad in cz’s eyes.