Not long after the deal was announced, the Trump administration negotiated a highly favorable AI chips deal benefitting MGX [I93], and shortly afterwards announced that MGX will take a 15% stake in the TikTok deal brokered by the Trump administration [I94]. For Binance, the SEC dismissed with prejudice a fraud and unregistered securities case looming over the company [I85] — one in which Binance’s Chief Compliance Officer was quoted admitting that “we are operating as a fking unlicensed securities exchange in the USA bro”. Now, Zhao has earned his pardon. And discussions to prematurely remove independent monitors installed to oversee Binance’s compliance programs seem to remain ongoing [I93]. Binance has also reportedly discussed other, more direct business deals with the Trumps, including the possibility that the family would take a stake in Binance’s US division [I79]. Such a deal has not yet emerged, though the pardon may be an attempt to mitigate reputational concerns that might otherwise complicate any future arrangement. And the pardon would certainly smooth the pathway for Binance to expand its business in the US — potentially with CZ back at the helm. (CZ was required to step down as CEO as part of his plea agreement, which also permanently banned CZ from regaining a leadership role at the company, though he has maintained substantial influence over the company and owns a majority of its shares.)

But while Trump acknowledged he was being urged behind the scenes to pardon the crypto billionaire, he did not address his own financial gains linked to Binance. Taken together, his personal profits and the subsequent executive leniency toward the company and its figureheads create the clear appearance of a quid pro quo — and only one of many swirling around crypto interests during Trump’s second administration. In May, Binance accepted a $2 billion investment from the Emirati investment fund MGX, denominated in the Trump family’s USD1 stablecoin. The stablecoin had only just been announced, and it would have been odd for either entity to wish to use a brand new, untested stablecoin for such a high-value transaction — that is, unless they both had substantial interests in buying favor from the president. With that $2 billion to invest in money market funds, World Liberty has likely already made around $35 million in interest from the Binance/MGX deal alone,a and they stand to make hundreds of millions if the stablecoins are not redeemed over Trump’s term. And Binance has promoted the USD1 stablecoin to customers on its platform, driving more business to the Trumps (though the Binance deal still comprises around 70% of the USD1 issued to date).

Nevertheless, the White House press secretary has positioned the pardon as relief from an unfair prosecution, asserting that “The Biden administration’s war on crypto is over” and describing Zhao’s conviction as evidence of the previous administration’s “desire to punish the cryptocurrency industry”. While the crypto industry and the Trump administration have tried to portray any regulatory oversight or enforcement in the crypto space as an unjust “war on crypto”, I think the Trump administration has overplayed its hand by describing this prosecution as such. Most outsiders can distinguish targeted enforcement against clear misconduct from hostility toward innovation, and excusing justifiable prosecutions as mere political persecution only serves to highlight how frequently the Trump administration and the crypto industry use this tactic to try to dodge justice, accountability, and reasonable regulatory oversight. In a statement to the press, Trump acknowledged that Zhao “had a lot of support... and so I gave him a pardon at the request of a lot of good people.” Some of these “good people” were lobbyists hired by Zhao and/or Binance, including BakerHostetler lawyer Teresa Goody Guillén. While she lobbied the president for Zhao’s pardon, Goody Guillén simultaneously represented Trump’s World Liberty Financial cryptocurrency project; she wrote the brief May retort from the company in response to Senator Blumenthal’s questions about Trump’s conflicts of interest [I83, 84, 90].

After months of lobbying, President Trump has pardoned Binance founder Changpeng Zhao. Zhao, who in 2017 founded what would later become the largest crypto exchange in the world, pleaded guilty in late 2023 to one felony charge of failing to maintain an effective anti-money laundering program at Binance. The company itself pleaded guilty to three additional charges: conspiracy to conduct an unlicensed money transmitting business and to fail to maintain an effective anti-money laundering program, conducting an unlicensed money transmitting business, and sanctions violations. CZ served four months of prison time, and was released in September 2024 [I68]. He paid a $50 million fine, and his company paid another $4.3 billion in penalties. The indictment was damning, with evidence suggesting that CZ himself had directed Binance to implement a sham compliance program that would fool US regulators into believing they were screening for suspicious or illicit activity, while simultaneously allowing illicit transactions to continue unimpeded. While the primary Binance platform was not permitted to serve US customers, the company actively encouraged US-based users to circumvent Binance’s own geofencing, with CZ instructing: “On the surface we cannot be seen to have US users but in reality, we should get them through other creative means.” Binance was simultaneously aware that it was offering services to sanctioned users, with the company’s Chief Compliance Officer writing that “There i