Noah Perlman, the Chief Compliance Officer at Binance, the world's largest cryptocurrency exchange, stated on Jan. 16 that he takes pride in the accomplishments of his team over the past year and anticipates continuing their efforts. One significant achievement Perlman noted during his tenure with Binance was reaching a settlement with the U.S. government.
"I joined Binance one year ago today with a mandate to help resolve legacy issues and to build a world-class compliance program that puts users first AND meets or exceeds regulatory expectations across the world," Perlman said. "It has been thrilling to partner with some of the greatest minds in crypto and I am excited to continue partnering with these innovators in the coming years. There is plenty more to do and I look forward to the road ahead!"
On Nov. 21, Binance reached a settlement with the U.S. government, agreeing to pay $4.3 billion in penalties to resolve historical compliance issues, as per a U.S. Department of Justice (DOJ) press release. As part of this resolution, Changpeng Zhao (CZ), CEO of Binance, agreed to step down from his role and plead guilty for failing to maintain an effective anti-money laundering (AML) program which violated the Bank Secrecy Act. Additionally, Binance consented to retain a third-party compliance monitor for three years. Treasury Secretary Janet Yellen referred to this settlement and monitorship as "historic" and "a milestone for the virtual currency industry."
In a post on its website, Binance stated that during two years leading up to this settlement it underwent "unprecedented scrutiny," revealing steps taken by Binance towards improving safety and security on its platform. The company also mentioned that improvements were highlighted by agencies such as U.S. Financial Crimes Enforcement Network (FinCEN), DOJ, and Office of Foreign Assets Control (OFAC).
According to FinCEN’s consent order, Binance "remodeled its compliance program governance and organization structure, including by hiring new compliance leadership with professional compliance experience in the financial sector and law enforcement." The DOJ's plea deal agreement stated that Binance had invested resources into improving its AML and countering the financing of terrorism (CFT) programs, "including by replacing ineffective compliance staff with experienced employees and significantly increasing compliance headcount."
In addition to the settlement, Perlman highlighted additional methods through which users can complete know-your-customer (KYC) verifications and over 100 law enforcement training sessions as other "milestones" achieved during his first year with Binance.
Binance's blog post also noted that FinCEN acknowledged Binance's partnership with law enforcement agencies worldwide to assist in tackling illegal activity. "Binance works closely with law enforcement agencies worldwide related to this type of illicit activity, including Hydra, darknet markets, and hacks," said FinCEN's consent order. The order also noted that Binance has "proactively cooperated with global law enforcement and blockchain vendors to combat terrorism financing." Furthermore, OFAC observed that Binance had created "two teams dedicated to cooperation with law enforcement, including by proactively sharing intelligence and responding to time-sensitive requests."
Before joining Binance, Perlman served as the chief compliance officer for the crypto exchange Gemini, as per an article on the Gemini website. Prior to his tenure at Gemini, Perlman spent 13 years at Morgan Stanley, including a stint as global head of financial crimes. He has also previously worked as division counsel for the United States Drug Enforcement Administration (DEA) New York Division and an Assistant United States Attorney (AUSA) for the Eastern District of New York.
