Corporate Crime Case Database
Consistent with the Department’s ongoing commitment to transparency in corporate crime cases, the DOJ launched a new case database. While it is still in the process of being populated, it will eventually contain the significant, relevant cases from each component and U.S. Attorney’s Office, resolved since the beginning of 2023.
United States v. Changpeng Zhao
On November 21, 2023, Binance’s founder and Chief Executive Officer, Changpeng Zhao, pleaded guilty to violating the BSA by causing Binance to violate the BSA by causing Binance to fail to implement an effective anti-money laundering program. Simultaneously, the Department of Justice announced that Binance Holdings Limited (Binance) pleaded guilty to conspiracy to violate the Bank Secrecy Act (BSA) and to fail to register as a money transmitting business, failure to register as a money transmitting business, and violating the International Emergency Economic Powers Act (IEEPA). Binance, the largest cryptocurrency exchange in the world, prioritized growth, market share, and profits over compliance with U.S. law in a deliberate and calculated effort to profit from the U.S. market without implementing controls required by U.S. law. Binance agreed to pay $4.3 billion in penalties and will undertake compliance enhancement and remediation and retain an independent monitor. This is the Department’s largest corporate guilty plea that also involves the guilty plea of a Chief Executive Officer. This prosecution was led by the Criminal Division’s Money Laundering and Asset Recovery Section, the National Security Division and the U.S. Attorney’s Office for the Western District of Washington.
United States v. Binance Holdings Limited, d/b/a Binance.com
On November 21, 2023, the Department of Justice announced that Binance Holdings Limited (Binance) pleaded guilty to conspiracy to violate the Bank Secrecy Act (BSA) and to fail to register as a money transmitting business, failure to register as a money transmitting business, and violating the International Emergency Economic Powers Act (IEEPA). Binance, the largest cryptocurrency exchange in the world, prioritized growth, market share, and profits over compliance with U.S. law in a deliberate and calculated effort to profit from the U.S. market without implementing controls required by U.S. law. Binance agreed to pay $4.3 billion in penalties and will undertake compliance enhancement and remediation and retain an independent monitor. Simultaneously, Binance’s founder and Chief Executive Officer, Changpeng Zhao, pleaded guilty to violating the BSA by causing Binance to violate the BSA by causing Binance to fail to implement an effective anti-money laundering program. This is the Department’s largest corporate guilty plea that also involves the guilty plea of a Chief Executive Officer. This prosecution was led by the Criminal Division’s Money Laundering and Asset Recovery Section, the National Security Division and the U.S. Attorney’s Office for the Western District of Washington.
United States v. British American Tobacco P.L.C., et al
British American Tobacco (BAT) and its subsidiary, BAT Marketing Singapore (BATMS), one of the world’s largest manufacturers of tobacco products based in the United Kingdom, pleaded guilty to criminal charges arising out of the companies’ scheme to do business in North Korea through a third-party company in Singapore, in violation of the bank fraud statute and the International Emergency Economic Powers Act (IEEPA). The companies agreed to pay combined penalties of more than $629 million to resolve bank fraud and sanctions violations charges with U.S. authorities.
BATMS pleaded guilty to a criminal information filed in the U.S. District Court for the District of Columbia charging BAT and BATMS with conspiracy to commit bank fraud and conspiracy to violate IEEPA. BAT entered into a deferred prosecution agreement related to the same charges.
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United States v. Sim Hyon-Sop, et al
The Department of Justice brought charges a North Korean banker and Chinese facilitators for their roles in facilitating the illicit sale of tobacco products in North Korea. As alleged, the defendants engaged in a scheme to purchase leaf tobacco for North Korean state-owned cigarette manufacturers and used front companies and false documentation to cause U.S. financial institutions to process at least 310 transactions worth approximately $74 million that they otherwise would have frozen, blocked, investigated, or declined, had they known that the transactions were connected to trade in North Korea. The transactions generated an estimated revenue amount of up to $700 million for the North Korean manufacturers, one of which was owned by the North Korean military.
As alleged in the indictment, cigarette trafficking, including counterfeit cigarettes, generates significant revenue for advancing North Korea’s weapons of mass destruction programs, including its nuclear weapons.
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United States v. NuDay, a/k/a NuDay Syria
On September 8, 2023, NuDay, a/k/a NuDay Syria, a not-for-profit charity, pleaded guilty to three counts of Failure to File Export Information, in violation of 13 U.S.C. § 305. Between 2018 and 2021, NuDay used a freight forwarding company to export over 100 shipments of donated humanitarian goods to Turkey, where another company would transship them into Syria, a country subject to economic sanctions and export restrictions. NuDay caused its freight forwarder to fail to file export information required to be filed by U.S. Department of Commerce regulations by falsely reporting to the freight forwarder that the end-user of the shipments was located in Turkey and not Syria, and by artificially deflating the value of the humanitarian goods to be below the reporting threshold.
As part of its plea agreement, NuDay agreed to a term of five years’ probation which includes the condition that NuDay’s founder and her family have no further involvement with NuDay, and to pay a $25,000 fine.
Press Release: NuDay Charity Pleads Guilty in Connection with the Illegal Export of Goods to Syria
United States v. Empire Navigation Inc. and Suez Rajan Limited
On April 19, 2023, Suez Rajan Limited, the bareboat charterer of the oil tanker Suez Rajan, pleaded guilty to conspiring to violate the International Emergency Economic Powers Act (IEEPA) and economic sanctions against Iran, in connection with a scheme to covertly sell and transport for Iran’s Islamic Revolutionary Guard Corps (IRGC) 980,000 barrels of Iranian crude oil to a customer abroad. On that same date, the company was sentenced by U.S. District Court Judge Carl J. Nichols for the District of Columbia to three years of corporate probation and a fine of almost $2.5 million.
In addition, pursuant to a deferred prosecution agreement (DPA) and a seizure warrant issued by the U.S. District Court for the District of Columbia, Empire Navigation Inc., the operating company of the vessel carrying the contraband cargo, agreed to be jointly liable for the fine imposed on Suez Rajan Limited, to cooperate with the government, and to transport the Iranian oil to the United States for seizure.
Related Case: United States v. All Petroleum-Product Cargo Aboard the Suez Rajan with International Maritime Number 9524475, 23-CV-00882-CJN (D.D.C.)