DOJ Reviews Binance Compliance With 2023 Settlement Amid Iran Sanctions Scrutiny

The U.S. Department of Justice is reviewing Binance’s compliance with its 2023 settlement, focusing on potential violations of U.S. sanctions against Iran. Investigators are reportedly concentrating on activity that occurred after the November 2023 settlement.

Binance reached a significant settlement with U.S. authorities in November 2023, agreeing to pay over $4.3 billion in total penalties, including $2.51 billion in forfeitures and a $1.81 billion fine paid to the DOJ. As part of this agreement, Binance admitted to violating the Bank Secrecy Act, the primary U.S. anti-money laundering law, and consented to a three-year DOJ monitorship.

In 2024, Binance appointed two independent monitors: Forensic Risk Alliance for a three-year oversight role and Sullivan & Cromwell for a five-year assignment. The exchange’s founder, Changpeng Zhao, pleaded guilty in 2023, was fined $50 million, and stepped down as CEO.

The current DOJ review is examining whether Binance knowingly processed transactions that should have been blocked, specifically those involving Hong Kong entities accused of facilitating payments tied to Iranian oil sales. This scrutiny extends to whether such activities continued after the November 2023 settlement.

On September 15, 2026, the DOJ filed a civil forfeiture action seeking $61 million in digital assets connected to these flows. Binance was not named as a defendant in this forfeiture action.

Binance has stated that it maintains a zero-tolerance policy toward sanctions violations and is committed to compliance. The exchange points to its practice of offboarding accounts linked to suspicious activity, noting that such accounts were removed in August 2025 and January 2026.

Several key uncertainties surround the ongoing review. It remains unclear whether Binance knowingly processed transactions that its systems should have blocked, and whether the exchange has fully lived up to the terms of its settlement. The outcome of the DOJ’s review is not yet determined. Observers are watching to see if the review yields formal findings regarding Binance’s post-settlement conduct, if the $61 million forfeiture case reveals further details about the financial flows involving the Hong Kong entities, and how the ongoing monitorships unfold. The three-year term for Forensic Risk Alliance and the five-year term for Sullivan & Cromwell provide a sustained period for regulatory oversight.

Binance has not been formally charged with new violations, nor was it a defendant in the September 2026 forfeiture case.

Why This Matters

The materials describe a narrow update: The DOJ is investigating whether Binance knowingly processed transactions that should have been blocked, specifically those involving Hong Kong entities accused of facilitating payments tied to Iranian oil sales, and whether this occurred after the November 2023 settlement. Whether Binance knowingly processed transactions that its systems should have blocked.

Broader Context

Source materials place the factual news in this context: The November 2023 settlement was one of the largest corporate penalties in crypto history.