DOJ Criminal Division Chief Tysen Duba Says Department Is Reviewing Binance's Compliance With 2023 Settlement

Since Bloomberg reported on Sept. 22 that Manhattan federal prosecutors and the Justice Department's Criminal Division were examining Binance's handling of Iran-linked transactions, a senior DOJ official has put the review on the record. Tysen Duba, chief of the Criminal Division, said in an interview this week that the department is reviewing Binance's compliance with its 2023 settlement agreement.

Duba declined to discuss specific facts or the progress of the investigation. He did not assert that Binance has violated the agreement.

What prosecutors are examining

The U.S. Attorney's Office for the Southern District of New York is leading the work with the Criminal Division. At issue is whether Binance knowingly processed or failed to block transactions that its controls should have stopped.

Investigators are reportedly concentrating on activity after the November 2023 settlement, not before it. The specific transactions under review have not been identified, and the DOJ and the Manhattan office declined comment when the probe first surfaced.

No new charges have been filed against Binance. Justice Department probes do not always end in charges.

The forfeiture case

In mid-September, prosecutors filed a civil forfeiture complaint in federal court in Manhattan seeking $61 million in USDT. The government says the funds trace to sales of sanctioned Iranian crude oil and petroleum products. Prosecutors allege proceeds were meant to be shared with the Iranian government and military organizations, including the Islamic Revolutionary Guard Corps.

The complaint names two Chinese companies, Blessed Trust and Hexa Whale. Prosecutors allege they used Binance trading accounts and that the wider network laundered more than $1.5 billion in proceeds from illegal oil sales.

The complaint targets the cryptocurrency at specific addresses. It does not allege wrongdoing by Binance, and Binance is not a defendant. The government itself notes that civil forfeiture allegations are unproven unless a court enters judgment.

Binance's position

Binance says it has a zero-tolerance policy on sanctions violations and works with law enforcement. It says its know-your-customer rules bar anyone resident in or located in Iran from using Binance.com. The company has also said it has found no evidence of Iranian involvement.

On the two accounts named in the complaint, Binance gives this timeline:

• Law enforcement contacted it in April 2025 about Hexa Whale and other addresses tied to terrorism financing.
• It handed over KYC and transaction information in June 2025.
• It delisted Hexa Whale in August 2025.
• Blessed Trust went through source-of-funds checks and was offboarded in January 2026.

In a February blog post, Binance said more than 1,500 employees, roughly a quarter of its global workforce, work on compliance.

The 2023 deal

The size of the original agreement is what raises the stakes. In November 2023 Binance pleaded guilty to Bank Secrecy Act violations, operating an unlicensed money-transmitting business and sanctions-related violations. Total penalties topped $4.3 billion, including $2.51 billion in forfeiture and a $1.81 billion fine paid to the DOJ.

Binance admitted it failed to build controls to keep U.S. customers from trading with users in sanctioned jurisdictions. It agreed to a three-year DOJ monitorship on anti-money-laundering compliance and to exit the U.S. market. In 2024 it appointed two independent monitors: Forensic Risk Alliance on a three-year term and Sullivan & Cromwell on a five-year term.

Founder Changpeng Zhao pleaded guilty, stepped down as CEO and served four months in prison. President Donald Trump pardoned him last year. No source ties the pardon to the current review.

If prosecutors conclude Binance breached the agreement, additional prosecution or fines are possible. That outcome is hypothetical today. Duba made no such finding.

What comes next

Two things will show where this goes. One is whether the Manhattan office and the Criminal Division produce formal findings on Binance's post-settlement conduct. The other is whether the forfeiture litigation over the $61 million surfaces more detail on how Blessed Trust, Hexa Whale and related entities moved money through Binance accounts, and when.