US Recruitment: Global Cryptocurrency Exchange

Author: Liu Honglin, Manqun Blockchain Legal Services

TechFlow Digest: From the funds transfer ban on Matcha (MEXC), to Binance’s guilty plea and executive pardon, to Intercontinental Exchange’s strategic minority stake in OKX, U.S. regulators and Wall Street capital are systematically absorbing the global offshore crypto trading sector through a dual drive of “long-arm jurisdiction” and commercial integration.

This article, deeply analyzed by lawyer Liu Honglin of Manqun Law Firm, reveals how the cross-border liquidity channels paved over more than a decade by global crypto exchanges are being comprehensively penetrated from the top down by U.S. dollar stablecoins and traditional financial institutions, rendering offshore crypto forces irreversibly moving toward institutionalized integration.

On November 6, the U.S. Treasury Department took action against yet another cryptocurrency exchange. This time, the targeted platform was Matcha, also known as MEXC.

The Financial Crimes Enforcement Network (FinCEN), a bureau under the U.S. Treasury Department, issued an order prohibiting U.S. financial institutions from processing fund transfers involving MEXC. According to the official announcement, U.S. authorities determined that the platform processed at least $16 billion related to sanction evasion, cybercrime, and other offenses between May 2021 and May 2026, involving Iran, North Korea, and Russia.

The order will take effect 30 days after publication in the Federal Register. MEXC subsequently responded that its deposits, withdrawals, and trading were functioning normally, and that it was reviewing the order and preparing to communicate with regulators. However, the conditions set by the U.S. are already quite explicit. In the announcement, Treasury Secretary Bessent framed continued access to the U.S. financial system and support for the Iranian regime as a binary choice.

Image: Announcement of the funds transfer ban on Matcha from the official FinCEN website

Reading this news, I’m reminded of the predicament faced by exchange founders over the past few years. Platforms have expanded globally, users are distributed across countries, and registration jurisdictions can be changed repeatedly. But once a business grows large enough, it ultimately has to seriously address the questions posed by the United States.

In a sense, the United States is systematically co-opting global cryptocurrency exchanges. Those willing to align can negotiate investments, partnerships, and market entry into the U.S. Those unwilling or unable to accept the conditions may face investigations, prosecutions, and the consequence of having their financial channels cut off.

For exchanges that still aim to serve mainstream global capital, the cost of remaining outside this system is becoming increasingly high.

The Aligners: Look at Binance

To understand today’s Binance, one must start in November 2023.

That month, Binance reached criminal and related enforcement settlement arrangements with the U.S. Department of Justice and other agencies, agreeing to pay over $4.3 billion. Zhao Changpeng pleaded guilty and stepped down as CEO. Despite occupying a critical position in the global crypto market, the platform ultimately had to resolve its past operations within the U.S. legal framework.

The violations cited by the U.S. were highly specific: the platform served U.S. customers without fulfilling corresponding anti-money laundering obligations, and engaged in transactions violating U.S. sanctions regimes.

What merits closer attention than the fines themselves are the operational conditions tied to the settlement. Under the arrangement announced by the U.S. Treasury Department at the time, Binance was required to submit to five years of compliance oversight. Regulators could access its books, records, and systems through appointed monitors, and verify the execution of commitments such as exiting the U.S. market.

For an exchange, this directly alters the way it generates revenue. If the platform wishes to continue operating, its growth teams must accept that the compliance department has the authority to block certain revenue streams.

However, Binance’s subsequent moves indicate that its founders do not intend to remain confined to merely paying fines.

In December 2024, Binance announced a strategic partnership with Circle, the issuer of the U.S. dollar stablecoin USDC. Binance would expand the use of USDC across products such as trading and payments, and incorporate it into corporate treasury management. Circle, in turn, provided technological and liquidity support. An exchange serving global users and a U.S. stablecoin company began jointly scaling the on-chain dollar business.

In 2025, Binance secured a $2 billion minority equity investment from Abu Dhabi-based investment firm MGX. In May of the same year, co-founders of World Liberty Financial announced at a Dubai event that this investment was settled using USD1, the U.S. dollar stablecoin issued by the project. As World Liberty Financial is affiliated with the Trump family, this Middle Eastern capital investment in the exchange became linked to crypto ventures involving an American political family.

The funding came from an Abu Dhabi institution, the settlement tool originated from a project backed by the Trump family, the exchange secured financing, and the stablecoin gained a major application scenario. Each participant had its own commercial interests, further intertwining their respective businesses.

In October 2025, Zhao Changpeng received a presidential pardon from Trump.

The pardon document addressed Zhao’s specific federal crimes. We can already see that the relationship between exchange founders and the United States is built through law enforcement, but continues to evolve through commercial interests and political engagement.

The so-called “alignment” is often completed within these concrete arrangements. The company continues to operate, founders continue to seek development opportunities, while U.S. compliance requirements, commercial partners, and dollar-denominated products penetrate deeper into the daily operations of exchanges.

Image: Relevant documents regarding Zhao Changpeng receiving a U.S. presidential pardon

OKX Secures Its Wall Street Ticket

While Binance chose to expand cooperation with U.S. stablecoin companies, OKX went a step further, bringing U.S. financial institutions into its shareholder base and board of directors.

On March 5, 2026, the Intercontinental Exchange (ICE), parent company of the New York Stock Exchange, announced its investment in OKX at a valuation of $25 billion. The announcement did not disclose the exact investment amount but explicitly stated that ICE would secure a board seat at OKX.

Image: Official press release on Intercontinental Exchange’s investment in OKX

A single board seat elevates cooperation into corporate governance and operational discussions. For OKX, this new partner brings access to mature regulated markets, institutional clients, and financial product resources. Consequently, the platform’s previously accumulated global user base gains the opportunity to engage with more traditional financial assets.

OKX has amassed crypto users, wallets, and trading infrastructure, while ICE possesses products and institutional resources from the U.S. financial market. Following the partnership, the former can expand its product offerings, while the latter can reach previously untapped investors through the crypto platform. This gives U.S. financial institutions an opportunity to bring their markets to users in more countries via a global exchange.

The plans announced by both parties are clear. ICE will obtain a license to OKX’s spot crypto price data to launch U.S. regulated futures products. Upon receiving relevant regulatory approvals, OKX plans to provide its users with access to ICE’s U.S. futures market and the NYSE tokenized stock market.

Nevertheless, OKX had to first resolve U.S. enforcement issues before reaching this stage.

U.S. prosecutors revealed that although OKX restricted U.S. users in its policies, it continued to attract and serve American customers. Individual employees even advised clients to provide false information to bypass identity verification. In February 2025, the Seychelles entity Aux Cayes FinTech, which operated OKX, pleaded guilty and agreed to pay forfeitures exceeding $504 million. Under the plea agreement, its independent compliance consultant arrangement extends until at least February 2027.

Garantex Rebrands, U.S. Sanctions Continue

Of course, there are always two paths in the woods, and some people inevitably choose the less-traveled one.

This pressure has been weighing on Russian exchange Garantex for several years. In April 2022, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) designated Garantex on its sanctions list. This office is responsible for enforcing U.S. economic sanctions. After being listed, Garantex continued operations, and the platform and associated individuals remained under investigation.

Even an offshore exchange that does not maintain a physical presence in the U.S. may require connections to American banks, payment services, or other regulated entities. By controlling these intermediaries, the U.S. can dictate the conditions under which an exchange interacts with external capital. Overseas partners who wish to retain their own U.S. business operations will also weigh whether to continue bearing the costs of partnering with designated platforms.

In March 2025, acting jointly with Germany and Finland, the U.S. seized the domain names and servers used by Garantex. Simultaneously, the U.S. Department of Justice filed charges against related operators and disclosed the freezing of over $26 million in associated funds. The pressure faced by the exchange expanded from financial restrictions to website infrastructure, assets, and actual operators.

Image: Screenshots released by the U.S. Department of Justice showing the seizure of the Garantex website

Garantex subsequently attempted to relocate its customers and funds. According to an August 2025 U.S. Treasury announcement, its successor platform Grinex absorbed part of the business, utilizing a ruble-backed token called A7A5 for related arrangements. The United States continued to add Grinex, along with associated individuals and entities, to its sanctions lists.

This experience demonstrates that even after leaving the U.S.-led financial network, an exchange can still find clients and continue processing substantial volumes of transactions. However, it must constantly seek new infrastructure and partnerships while enduring further rounds of tracking and sanctions. The more a platform relies on such clients, the harder it becomes to secure the funding and services offered by mainstream financial institutions, increasingly constraining its business options.

For exchange founders aiming for long-term survival, these are costs that must be carefully calculated.

Once Funds Are On-Chain, Can the U.S. Still Enforce Control?

Many readers might pause here with a question: If traditional banking channels can be cut off, could an exchange simply limit itself to crypto-to-crypto trading, routing all funds on-chain, thereby reducing U.S. influence?

On March 7, 2025, Tether publicly stated that it had assisted the U.S. Secret Service in freezing $23 million in funds linked to transactions associated with Garantex. Tether’s USDT is a commonly used U.S. dollar stablecoin in the crypto market. While users holding private wallet keys can initiate transactions independently, the token contract retains administrative controls for the issuer. Once a specific address is frozen by the issuer, the USDT held at that address becomes subject to transfer restrictions.

As early as December 2023, Tether announced a voluntary wallet freeze policy, taking action against activities linked to OFAC’s Specially Designated Nationals and Blocked Persons List, including freezing wallets already designated on that list.

What does this mean for exchanges?

An exchange can locate its headquarters outside the U.S. and exclusively handle crypto assets. Yet, as long as its operations heavily rely on centrally issued U.S. dollar stablecoins like USDT, it must still account for the issuer’s compliance policies and freezing capabilities.

Thus, U.S. influence over the crypto market now operates simultaneously across both traditional banking and blockchain layers. Banks determine which fiat transfers can be processed, stablecoin issuers decide how to execute freezes on their tokens, and trading platforms restrict accounts or transactions based on compliance lists and risk policies.

Image: Issuers can restrict transfers of related tokens for specific addresses via smart contracts

The more an exchange strives to attract institutional clients and traditional financial products, the greater the need to prove its ability to identify these boundaries and enforce these requirements. On-chain operations are thus pulled into the scrutiny frameworks of mainstream financial partners.

The U.S. Cash-In on Exchanges’ Global Customer Base

Viewing Binance, OKX, MEXC, and Garantex together makes the U.S. stance toward exchanges increasingly clear.

For illegal activities, the U.S. responds with investigations, prosecutions, and penalties. For platforms willing to accept conditions and possessing commercial value, U.S. financial institutions are ready to invest and collaborate. Law enforcement agencies, presidents granting pardons, and profit-driven private firms each pursue distinct objectives, but cumulatively, these actions compel exchanges to prioritize U.S. regulations and relationships.

Policies, of course, shift. In January 2025, the operating entity behind BitMEX was fined $100 million for violations of the Bank Secrecy Act, only to receive a presidential pardon alongside several founders in March of the same year. The United States that exchanges navigate harbors differing law enforcement judgments, political choices, and commercial interests internally. Consequently, the networks founders must manage extend beyond counsel and regulators to include financial partners and the broader political landscape.

This reality makes “pro-U.S.” alignment an increasingly pragmatic operational strategy.

In the past, many exchanges could rapidly acquire users through lax onboarding requirements, diverse token listings, and cross-border services. Once scale increases and the demand grows for more stable banking services, more attractive assets, and greater institutional capital, the U.S.-dominated financial network invariably resurfaces in the next phase of development planning.

Global exchanges have completed user education, built robust trading and wallet infrastructure, and accumulated multinational distribution capabilities. By integrating with these platforms, U.S. financial institutions gain opportunities to enable more international users to trade their products and utilize assets priced and settled in U.S. dollars.

For exchanges, this represents a commercially viable venture. Yet, as revenue becomes increasingly reliant on these partnerships, platforms will proactively filter clients, manage assets, and structure operations in ways acceptable to their partners. The influence of U.S. regulations will consequently expand beyond American borders, riding alongside product rollout and capital flows.

Therefore, when stating that the United States is systematically co-opting global cryptocurrency exchanges, the most critical aspect to watch is this structural shift. Platforms willing to cooperate can share in the profits of accessing mainstream financial markets. Those persistently running business lines excluded by the U.S. sanctions regime must endure higher connectivity costs and enforcement pressures.

Cryptocurrency exchanges spent over a decade connecting users worldwide. Today, U.S. financial institutions and dollar-denominated products are traversing these established pipelines, flowing directly into more and more individual accounts.