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Case 1:23-cv-01599-ABJ Document 21 Filed 06/07/23 Page 1 of 27

UNITED STATES DISTRICT COURT


FOR THE DISTRICT OF COLUMBIA

__________________________________________
SECURITIES AND EXCHANGE )
COMMISSION, )
)
Plaintiff, )
)
v. ) Civil Action No. _______
)
BINANCE HOLDINGS LIMITED, )
BAM TRADING SERVICES INC., )
BAM MANAGEMENT US HOLDINGS )
INC., AND CHANGPENG ZHAO, )
)
Defendants. )
__________________________________________)

DECLARATION OF SACHIN VERMA

I, Sachin Verma, declare the following pursuant to Title 28, United States

Code, Section 1746:

1. I am an active Certified Public Accountant with over 20 years of

experience. I am currently employed by the United States Securities and Exchange

Commission (“SEC”) in Washington, DC, as an Assistant Chief Accountant in the

Division of Enforcement. As part of my daily activities, I have performed numerous

reviews of financial records in connection with SEC investigations.

2. I submit this declaration in support of the SEC’s Motion for a

Temporary Restraining Order and Preliminary Injunctions. The information set

forth herein is based upon my personal review of financial records such as bank

statements, deposits, cancelled checks, wire transfers, signature cards, and other

account documents produced to the SEC by the defendants, Silvergate Bank,


1
Case 1:23-cv-01599-ABJ Document 21 Filed 06/07/23 Page 2 of 27

Signature Bank, FedWire and other parties pursuant to subpoenas and document

requests (“financial records”) as of this date. My classification and summarization of

financial records in this Declaration may change based on additional information that

may be produced at a later date.1 I have cited to bates stamped document where

applicable (“record documents”).

3. During the period from April 18, 2019 to April 5, 2023 (the “Relevant

Period”), the corporate Defendants and many other corporate entities owned by

Defendant Zhao held numerous accounts with two banks in the United States--

Silvergate Bank and Signature Bank.

4. According to their websites, both banks had proprietary networks

designed to enable their digital currency and institutional investor customers to send

U.S. dollars and euros 24 hours a day between their accounts and the accounts of

other bank customers. Silvergate promoted its SEN network as “Real-time USD and

EUR settlement between counterparties, used by some of the largest exchanges in the

world,” and “enabling near real-time transfers and immediate availability of funds.”

Signature promoted its Signet Platform as leveraging blockchain technology to allow

its commercial clients to make payments in U.S. dollars 24 hours a day, and

“transactions made on the Signet Platform settle in real time, are safe and secure and

incur no transaction fees.”2

2
1
Given the volume of the documents, they are not being attached, but can made
available upon the Court’s request to the SEC’s counsel of record.
2
Wayback Machine for January 2023: Signet | Signature Bank (archive.org);
Wayback Machine December 2022: Silvergate Exchange Network Solutions |
Silvergate Bank | San Diego (archive.org).
Case 1:23-cv-01599-ABJ Document 21 Filed 06/07/23 Page 3 of 27

5. I have reviewed account statements produced by Silvergate Bank for

the following company accounts: Binance Holdings Limited, Binance Capital

Management Co Ltd., BAM Management US Holdings Inc., BAM Trading Services

Inc., Binance (Switzerland) AG, Sigma Chain AG, Merit Peak Limited, and Key

Vision Development Limited. Many of those accounts participated in the SEN

network.

6. I have reviewed account statements produced by Signature Bank for

the following company accounts: Binance Holdings Limited, Binance Capital

Management Inc., BAM Management US Holdings Inc., BAM Trading Services Inc.,

and Merit Peak Limited. Dozens of other Binance and non-Binance entities, all

beneficially owned by Zhao, also held accounts at Signature Bank. Many of these

bank accounts participated in the Signet network.

7. Attachment 1 summarizes the monthly activity in the Silvergate and

Signature bank accounts of the above-mentioned companies and provides an overview

of significant amounts of money moving through these accounts during 2019-2023,

including through SEN and Signet accounts described above. Attachments 2 and 3

summarize the corporate domicile, the beneficial owner, officers and signatories

during the relevant period.

SILVERGATE ACCOUNTS

8. The following is a summary of account activity in the above-mentioned

accounts at Silvergate Bank during the relevant period:

3
Case 1:23-cv-01599-ABJ Document 21 Filed 06/07/23 Page 4 of 27

KEY VISION DEVELOPMENT LIMITED

a. Key Vision Development Limited is a Seychelles company

beneficially owned by Zhao. The website address was identified as

“Binance.com,” the email address was identified as [email protected],

and the number of employees was disclosed as “1000 (Binance).” The nature of

its business was described as a cryptocurrency exchange to allow users to

exchange digital assets. The expected funds flow activity was described as

“Deposits: Fiat is wired to bank account, transfer fee paid at this point, Fiat

will automatically convert to stablecoin (BUSD) when deposited. Withdrawals:

BUSD converted to USD and withdrawn to client’s account.”

b. In 2020 and 2021, Key Vision deposits and withdrawals both

exceeded $13 billion (or $11 billion if internal transfers between Key Vision

accounts at Silvergate Bank are excluded). Nearly all of the funds deposited

into Key Vision accounts were transferred to an account in the name of Merit

Peak Limited. Silvergate closed Key Vision’s accounts in mid-2021.

MERIT PEAK LIMITED

c. Relevant Merit Peak Limited financial records show that Merit

Peak Limited is a British Virgin Islands company beneficially owned by Zhao.3

Its email address was identified as [email protected], and the nature of

its business was described as OTC desk and proprietary trading of digital

assets. Silvergate closed Merit Peak’s accounts in mid-2022.

4
3
BHL-SEC-BUSD-0021710.
Case 1:23-cv-01599-ABJ Document 21 Filed 06/07/23 Page 5 of 27

d. Between 2019 and 2021, Merit Peak accounts received $22 billion,

including approximately $11 billion from Key Vision, $7.2 billion from other

Binance entities, and $1.2 billion from BAM Trading. Merit Peak paid most of

that money - $21.6 billion - to a foreign affiliate of Paxos TrustCompany, LLC

(“Paxos”) the issuer of BUSD, a so-called stablecoin. This is summarized here:

Merit Peak Limited 2019-2021 2019-2021


Deposits Withdrawals

Silvergate Bank Account

Key Vision Development Limited $11,076,701,000

Binance Entities $7,187,710,000

BAM Trading Services Inc. $1,207,794,133

Paxos Global PTE LTD $21,557,032,027

Other $2,475,399,939 $390,573,045

Total $ 21,947,605,072 $21,947,605,072

Silvergate Bank Account $287,729,139 $287,729,139

Total $22,235,334,211 $22,235,334,211

SIGMA CHAIN

e. Sigma Chain AG is a Swiss company beneficially owned by Zhao.4

Sigma Chain’s described business was as a market maker providing liquidity

to fiat exchanges. Sigma Chain’s account was closed in February 2023.

f. Between 2019 and 2023, Sigma Chain’s account received $494

million, including $184 million from Binance Holdings Limited, $145 million

5
4
SEC-SGB-E-0022457.
Case 1:23-cv-01599-ABJ Document 21 Filed 06/07/23 Page 6 of 27

from BAM Trading, $36 million from Binance Capital Management, and $15

million from Key Vision. During that period, Sigma Chain paid $494 million,

including $160 million to BAM Trading Services, $131 million to Binance

Holdings Limited, $21 million to Merit Peak , $2 million to Binance

(Switzerland) AG, $32 million to Guangying Chen, and $10 million to Simpson

Marine. This is summarized here:

Sigma Chain Limited 2019-2023 2019-2023 Select


Select Withdrawals
Deposits

Silvergate Bank Account

Binance Holdings Limited $184,250,000 $131,188,691

BAM Trading Services Inc. $145,000,100 $160,000,600

Binance Capital Management Co $36,000,000


Ltd

Key Vision Development Limited $15,000,000

Merit Peak $21,000,100

Guangying Chen $32,430,435

Simpson Marine (S.E.A.) Pte Ltd $10,973,407

Binance (Switzerland) AG $2,253,649


Binance Capital Management Co $1,000,000
Ltd

Other $113,382,576 $134,780,183

Total $493,632,676 $493,627,065

BAM MANAGEMENT US HOLDINGS INC.

g. BAM Management US Holdings Inc., is a Delaware Company

owned by BAM Management Company Limited, all of which is beneficially

6
Case 1:23-cv-01599-ABJ Document 21 Filed 06/07/23 Page 7 of 27

owned by Zhao.5 The last transaction date is February 22, 2023. Between

2019 and 2023 deposits and withdrawals exceeded $500 million.

BAM TRADING SERVICES, INC.

h. BAM Trading Services Inc., is a Delaware company owned by

BAM Management US Holdings, Inc.6 Between 2019 and 2023, deposits and

withdrawals for these accounts exceeded $11 billion. It received $4 billion from

Prime Trust, $2.4 billion from Wintermute, $760 million from Subspace

Capital LLC, $424 million from Coinbase, $380 million from KBIT Global, $349

million from Auros Tech Limited, $326 million from Tagomi Trading LLC, $318

million from Alameda Research Ltd Debtor in Possession, $160 million from

Sigma Chain, $27 million from BAM Management Holdings, and $5 million

from Merit Peak Limited. It sent $3.3 billion to Wintermute Trading, Limited,

$1.5 billion to Alameda Research Ltd Debtor in Possession, $1.2 billion to Merit

Peak Limited, $924 million to Auros Tech Limited, $683 million to Subspace

Capital LLC, $665 million to KBIT Global Limited, $145 million to Sigma

Chain.

BINANCE (SWITZERLAND) AG

i. Binance (Switzerland) AG is a Swiss company beneficially owned

by Zhao.7 This account was closed in February 2023. Between 2019 and 2023,

deposits and withdrawals for this account exceeded $300 million, most of which

was received from Binance Holdings Limited, and paid out to a variety of

7
5
BHL-SEC-BUSD-0220886.
6
BTS00462320.
7
SEC-SGB-E-0022453.
Case 1:23-cv-01599-ABJ Document 21 Filed 06/07/23 Page 8 of 27

companies, including other Binance entities, and $20.6 million in 2022 to a

company beneficially owned by Guangying Chen, and $27.8 million to a

company beneficially owned by Zhao. This is summarized here:

Binance Switzerland AG 2019-2023 2019-2023 Select


Select Withdrawals
Deposits

Silvergate Bank Account

Binance Holdings Limited $290,950,000

Chaintecs Consulting Singapore $27,761,443


Pte.

Binance Europe Ltd. $23,781,131

Binary Technology Development $20,612,531


Pte.

BINANCE HOLDINGS LIMITED

j. Binance Holdings Limited is a Cayman Islands company

beneficially owned by Zhao.8 Between 2019 and 2023, deposits and

withdrawals for these accounts exceeded $6 billion. These accounts received

approximately $5.6 billion from Binance Holdings Limited Signature Bank

account, $131 million from Sigma Chain, $95 million from Merit Peak Limited,

$5 million from Key Vision, and $17 million from Binance Capital Management

Co. Limited, and paid approximately $4.2 billion to Merit Peak, $442 million to

Binance Capital Management Company Limited, $270 million to Binance

(Switzerland) AG, $184 million to Sigma Chain, and $29 million to Key Vision.

This is summarized here:

8
8
SEC-SGB-E-0022398.
Case 1:23-cv-01599-ABJ Document 21 Filed 06/07/23 Page 9 of 27

Binance Holdings Limited 2019-2023 2019-2023 Select


Select Withdrawals
Deposits

Silvergate Bank Accounts


Binance Holdings Limited – Signature $5,672,812,271
Bank

Sigma Chain $131,188,691 $184,250,000

Merit Peak $95,063,978 $4,205,230,000

Binance Capital Management Co Ltd $17,000,500 $441,811,220

Binance (Switzerland) AG $270,000,000

Key Vision $5,000,000 $29,040,486

BINANCE CAPITAL MANAGEMENT COMPANY LIMITED

k. Binance Capital Management Company Limited is a British

Virgin Islands company beneficially owned by Zhao.9 Between 2020 and

2023, deposits and withdrawals for these accounts exceeded $480 million,

primarily through deposits from Binance Holdings Limited, and it paid

approximately $36 million to Sigma Chain, and $17 million to Binance

Holdings.

SILVERGATE ACCOUNT CLOSURES

l. On December 23, 2022, Silvergate informed Binance that it would

be closing accounts for Binance (Switzerland) AG, Sigma Chain, Binance

Capital Management Company, and Binance Holdings Limited, and directed

the transfer of funds to be completed by February 22, 2023, at which point the

9
9
SEC-SGB-E-0022071.
Case 1:23-cv-01599-ABJ Document 21 Filed 06/07/23 Page 10 of 27

accounts would be closed. As of March 31, 2023, all of the accounts had zero

balances.

SIGNATURE ACCOUNTS

10. Many of the foregoing companies also held accounts at Signature Bank.

Account information from Signature Bank includes the following:

BAM MANAGEMENT US HOLDINGS INC.

a. BAM Management US Holdings Inc., is a Delaware Company

beneficially owned by Zhao. Between 2022 and 2023, deposits and withdrawals

exceeded $350 million.

BAM TRADING SERVICES

b. BAM Trading Services is a Delaware Company beneficially owned

by Zhao. Between 2019 and2023, deposits and withdrawals exceeded $500

million.

MERIT PEAK LIMITED

c. Merit Peak bank accounts show no activity during the relevant

period.

KEY VISION DEVELOPMENT LIMITEDi

d. Key Vision is a Seychelles company beneficially owned by Zhao.

Between 2020 and 2023, deposits and withdrawals exceeded $5.6 billion.

BINANCE CAPITAL MANAGEMENT COMPANY LIMITED

e. Binance Capital Management is a British Virgin Islands company

beneficially owned by Zhao. Between 2021 and 2023, deposits and withdrawals

exceed $900 million. Further information is summarized as follows:


10
Case 1:23-cv-01599-ABJ Document 21 Filed 06/07/23 Page 11 of 27

Binance Capital Management 2021-2023 2021-2023


Company Limited Select Select
Deposits Withdrawals

Signature Bank Accounts

Binance Holdings Limited $783,000,000 $50,069,978

Swipewallet EU OU $45,564,454 $9,000,000

Cyber Shaft Enterprises Limited $4,695,079

Zhao Changpeng $62,500,000

INSURED AIRCRAFT TITLE $54,705,000


SERVICE, LLC

Flowbank SA FFC Binary Technology $46,975,166


Development PTE Ltd

BINANCE HOLDINGS LIMITED

f. Binance Holdings Limited is a Cayman company beneficially

owned by Zhao. Between 2020 and 2022, deposits and withdrawals were

approximately $12 billion. Further information is summarized as follows:

Binance Holdings Limited 2020-2022 2020-2022 Select


Select Withdrawals
Deposits

Signature Bank Accounts

Bifinity UAB $6,546,897,038

Worldpay B.V. $1,859,393,758

Wallet ID: xxxx $2,807,113,068

Binance Holdings Limited $5,557,501,000

Merit Peak $2,586,980,000

SWIPEWALLET EU OU $1,237,000,000

11
Case 1:23-cv-01599-ABJ Document 21 Filed 06/07/23 Page 12 of 27

Binance Capital Management Co. Ltd. $714,000,000

Binance Investments Company $199,000,000


Limited

Prime Link Management Limited $105,000,000

Binance Holdings (IE) Limited $57,000,000

Binance Technologies Limited $27,000,000

Binance (Services) Holdings Limited $27,000,000

Binance Technologies Limited $20,000,000

OTHER SIGNATURE BANK ACCOUNTS HELD BY ZHAO-OWNED


ENTITIES

g. Zhao was also the beneficial owner of numerous other foreign

companies with accounts at Signature Bank. These companies are foreign

domiciled, including in Canada, UAE, Seychelles, Singapore, Lithuania,

Kazakhstan, among others. These accounts were opened by a Binance.com

employee, with Zhao as the listed beneficial owner, and Guangying Chen as the

listed signatory. Some of these companies have “Binance” in their company

name. Other companies do not bear the Binance name, but accounts were

opened in the same fashion, listing Zhao as the beneficial owner and

Guangying Chen as the signatory. Their links to Binance are consistent with a

Binance organization chart10.

12
10
BHL-SEC-BUSD-0289617.
Case 1:23-cv-01599-ABJ Document 21 Filed 06/07/23 Page 13 of 27

SIGNIFICANT TRANSFERS

11. Binance Holdings Limited and Binance Capital Management show large

deposits and withdrawals from and to Signature accounts for some Zhao-owned

companies, and hundreds of millions of dollars have been transferred.

BIFINITY UAB TRANSFERS BILLIONS OF DOLLARS TO BINANCE


COMPANIES

a. Bifinity UAB (fka Binance UAB) is a company located in

Lithuania and beneficially owned by Zhao. The account opening documents

state that Bifinity UAB is in the business of “provid[ing] revenue collection for

Binance operators” conducting business in “Germany, UK, Netherlands and

Switzerland.” The listed signatories on Bifinity accounts include Guangying

Chen, and the account was opened by someone from Binance.com.11

b. Between 2020 and 2022, Bifinity UAB paid $6.5 billion to a

Binance Holdings Limited account. In 2021, that Binance Holdings Limited

account received $3 billion from Bifinity and $1.8 billion from WorldPay,12

making up the majority of deposits for the year. That money was transferred

in 2021 out of Binance Holdings Limited to Merit Peak in direct wires for $2.5

billion and transferred $4.8 billion to another Binance Holdings account at

Silvergate, which paid Merit Peak another $3.7 billion.

13
11
SIGB-H-0001-00000063.
12
WorldPay is a payments processing company that purports to provide Crypto
trading platforms with the ability to move fiat money in and out of cryptocurrency.
[https://www.protocol.com/fintech/worldpay-crypto-payments]. WorldPay paid
Binance Holdings Limited $1.76 billion in 2021.
Case 1:23-cv-01599-ABJ Document 21 Filed 06/07/23 Page 14 of 27

2021 Significant movements of money Select Select


between Zhao-owned entities Deposits Withdrawals

Binance Holdings Limited Signature


Bank Account

From Bifinity UAB Signature Bank Account $3,012,000,000

From Worldpay B.V. $1,859,393,757


To Binance Holdings Limited Silvergate $4,879,000,000
Bank Account

To Merit Peak Silvergate Account $2,586,980,000

Binance Holdings Limited Silvergate


Bank
From Binance Holdings Limited Signature $4,880,495,434
Bank

To Merit Peak Silvergate Bank Account $3,735,000,000

c. In 2022, Bifinity transferred another $3.5 billion to the same

Binance Holdings Limited account. $1.2 billion was transferred to an account

held by Swipewallet EU OU, another Zhao-owned company. Bifinity sent

another $304 million directly to Swipewallet. Swipewallet thereafter sent $1.5

billion in outgoing FX wires, in which USD is converted into a foreign currency

before transmitting to the beneficiary.

d. As for the rest of the money transferred by Bifinity, Binance

Holdings Limited distributed approximately $911 million to other Binance

Holdings accounts, $697 million to Binance Capital Management, and more

than $415 million to other Zhao-owned companies. One of those Zhou-owned

entities thereafter paid $62.5 million to a personal account held by Zhao, and

14
Case 1:23-cv-01599-ABJ Document 21 Filed 06/07/23 Page 15 of 27

in mid-March 2023 paid almost $47 million to a company beneficially owned by

Guangying Chen. On March 14, 2023, that account wired $29,613,891.93 to an

account held by Binance AP Holdings which was then wired out to the

company owned by Guangying Chen that same day, transfers that are

summarized here:

2022 Significant movements of money Select Select


between Zhao-owned entities Deposits Withdrawals

Binance Holdings Limited Signature


Bank Account
From Bifinity UAB Signature Bank $3,534,897,037
Account

To Swipewallet Eu Ou Signature Bank $1,237,000,000


Account

To Binance Holdings Limited Accounts


‐ Binance Holdings Limited $463,000,000
Silvergate Bank Account

‐ Binance Holdings Limited 448,000,000


Signature Bank Account

‐ Sub-total $911,000,000
To Binance Capital Management Co. Ltd. 697,000,000
Signature Bank Account

To Zhao-owned companies
‐ Binance Investments Co. Ltd. 162,000,000
Signature Bank Account

‐ Prime Link Management Limited $85,000,000


Signature Bank Account
‐ Binance Holdings (IE) Limited $57,000,000
Signature Bank Account

15
Case 1:23-cv-01599-ABJ Document 21 Filed 06/07/23 Page 16 of 27

2022 Significant movements of money Select Select


between Zhao-owned entities Deposits Withdrawals

‐ Binance Technologies Limited $27,000,000


Signature Bank Account

‐ Binance (Services) Holdings $27,000,000


Limited Signature Bank Account
‐ Swipewallet EU OU Signature $23,400,000
Bank Account

‐ Binance Technologies Limited $20,000,000


Signature Bank Account

‐ Other $13,695,750

‐ Sub-total $415,095,750

Swipewallet EU OU Signature Bank


Account
From Binance Holdings Limited $1,273,000,000
Signature Bank

From Bifinity UAB Silvergate Bank $304,000,000


Account

To Outgoing FX Wire $1,575,816,134

Binance Capital Management Co.


Ltd. Signature Bank Account
(includes select 2023 withdrawals
totaling $79,089,058*)
From Binance Holdings Limited $697,000,000
Signature Bank Account

To Zhao Changpeng Signature Bank $62,500,000*


Account ($60m in 2022 and $2.5m in
2023)

To Flowbank SA FFC Binary Technology $46,975,166*


Development PTE Ltd (a company
beneficially owned by Guangying Chen)

16
Case 1:23-cv-01599-ABJ Document 21 Filed 06/07/23 Page 17 of 27

2022 Significant movements of money Select Select


between Zhao-owned entities Deposits Withdrawals

To Binance (AP) Holding Limited $29,613,892*


Signature Bank Account; further
transferred from Binance (AP) Holdings
Limited on March 14, 2023 to Flowbank
SA FFC FFC Binary Technology
Development PTE Ltd (a company
beneficially owned by Guangying Chen)

BINANCE COMMINGLED FUNDS AT MERIT PEAK FOR FURTHER TRANSFER


TO PAXOS

12. Millions of dollars from Binance related accounts were commingled in

Merit Peak’s accounts. For example, in 2021, funds from Key Vision ($11.05 billion),

Prime Trust ($1.1 billion) (through BAM Trading) and Bifinity UAB ($6.3 billion)

(through Binance Holdings Limited) were transferred to Merit Peak and Merit Peak

transferred all of that money as part of its transfers of almost $20 billion to a foreign

affiliate of Paxos in 2021, summarized as follows:

2021 Merit Peak Select Account Select Deposits Select Withdrawals


Activity

Merit Peak Silvergate Bank Account

From Key Vision Development Limited $ 11,054,700,000

From Binance Holdings Limited $ 6,321,980,000

From BAM Trading Services Inc. $1,154,753,502

To Paxos Global PTE Ltd $19,975,961,032

LARGE AMOUNTS OF MONEY MOVE ACROSS BINANCE AND ZHAO-OWNED


BANK ACCOUNTS

13. The transactions in many of the Binance or Zhao-owned company

accounts held at Silvergate Bank and Signature Bank show large amounts of money

17
Case 1:23-cv-01599-ABJ Document 21 Filed 06/07/23 Page 18 of 27

flowing in and out of the accounts. The large incoming credits are followed by

outgoing debits within days, with the result that the accounts maintain a relatively

much lower balance at month’s beginning and end.

14. For example, in one Silvergate Binance Holdings 2022 account

statement, money is credited monthly from another Binance Holdings account,

accounting for most of monthly credits, and most of those credits are debited to

Binance Capital Management Limited and Binance Switzerland in interbank

transfers. In February 2022, for example, the account has a beginning balance of

$7.6M and an ending balance of $7.7M, but in that month $20 million was deposited

from another Binance Holdings account, $11M was wired to Binance Switzerland AG,

and $6M was wired to Binance Capital Management, as summarized here:

Feb 2022 Binance Holdings Limited Silvergate Deposits Withdrawals


Bank Account

From Binance Holdings Limited $20,000,000

To Binance (Switzerland) AG $11,000,000

To Binance Capital Management Co Ltd $6,000,000

Other $94,478 $2,944,633

Total $20,094,478 $19,944,633

15. This pattern of money flow repeats over months, as summarized here:

Month Op Bal U$ Credits # Credits US$ Debits # Debits US$ Cl Bal US$
Jun‐19 $0.00 2 $500,100.00 4 $10,100.00 $489,990.00
Jul‐19 $489,990.00 1 $1,000,000.00 18 $984,795.78 $505,194.22
Aug‐19 $505,194.22 0 $0.00 30 $285,127.80 $220,066.42
Sep‐19 $220,066.42 4 $1,234,385.00 78 $880,946.78 $573,504.64
Oct‐19 $573,504.64 8 $1,017,019.00 38 $1,221,165.05 $369,358.59
Nov‐19 $369,358.59 6 $2,029,321.10 126 $1,414,107.41 $984,572.28
Dec‐19 $984,572.28 14 $843,123.60 86 $1,118,487.47 $709,208.41
Jan‐20 $709,208.41 32 $4,125,860.47 110 $2,393,223.98 $2,441,844.90
Feb‐20 $2,441,844.90 24 $13,198,338.39 128 $3,269,227.65 $12,370,955.64

18
Case 1:23-cv-01599-ABJ Document 21 Filed 06/07/23 Page 19 of 27

Month Op Bal U$ Credits # Credits US$ Debits # Debits US$ Cl Bal US$
Mar‐20 $12,370,955.64 38 $38,782,117.78 116 $38,403,462.96 $12,749,610.46
Apr‐20 $12,749,610.46 32 $37,816,051.50 104 $33,842,419.03 $16,723,242.93
May‐20 $16,723,242.93 29 $15,676,090.45 106 $19,467,858.76 $12,931,474.62
Jun‐20 $12,931,474.62 90 $40,970,092.70 104 $20,622,814.43 $33,278,752.89
Jul‐20 $33,278,752.89 80 $49,078,856.96 122 $24,545,274.51 $57,812,335.34
Aug‐20 $57,812,335.34 68 $96,371,547.65 145 $93,282,559.04 $60,901,323.95
Sep‐20 $60,901,323.95 44 $123,915,287.67 116 $95,746,400.45 $89,070,211.17
Oct‐20 $89,070,211.17 31 $55,147,022.33 166 $20,301,712.96 $123,915,520.54
Nov‐20 $123,915,520.54 35 $62,021,156.50 146 $81,150,012.04 $104,786,665.00
Dec‐20 $104,786,665.00 20 $91,943,354.54 175 $129,090,458.91 $67,639,560.63
Jan‐21 $67,639,560.03 26 $183,316,090.57 143 $182,693,697.50 $68,261,953.70
Feb‐21 $68,261,953.70 22 $156,404,925.86 111 $174,525,739.29 $50,141,140.27
Mar‐21 $50,141,140.27 13 $445,542,017.62 157 $390,911,068.29 $104,772,089.60
Apr‐21 $104,772,089.60 13 $730,177,804.24 181 $727,463,722.90 $107,486,170.94
May‐21 $107,486,170.94 19 $607,146,622.44 155 $699,651,009.08 $14,981,784.30
Jun‐21 $14,981,784.30 22 $1,345,148,277.92 190 $1,356,483,954.81 $3,646,107.41
Jul‐21 $3,646,107.41 11 $689,091,808.59 175 $653,516,941.58 $39,220,974.42
Aug‐21 $39,220,974.42 10 $201,614,930.58 141 $194,182,505.70 $46,653,399.30
Sep‐21 $46,653,399.30 8 $131,746,373.38 138 $162,680,683.28 $15,719,089.40
Oct‐21 $15,719,089.40 14 $182,695,791.41 141 $176,397,036.13 $22,017,844.68
Nov‐21 $22,017,844.68 12 $170,671,158.88 124 $178,499,424.54 $14,189,579.02
Dec‐21 $14,189,579.02 20 $213,074,672.89 112 $220,832,010.62 $6,432,241.29
Jan‐22 $6,432,241.29 8 $125,131,745.39 95 $123,952,326.66 $7,611,660.02
Feb‐22 $7,611,660.02 5 $20,094,477.98 85 $19,944,633.00 $7,761,505.00
Mar‐22 $7,761,505.00 10 $63,055,614.46 118 $68,472,212.11 $2,344,907.35
Apr‐22 $2,344,907.35 8 $30,082,889.11 71 $26,153,168.03 $6,274,628.43
May‐22 $6,274,628.43 6 $20,029,852.77 96 $25,375,756.65 $928,724.55
Jun‐22 $928,724.55 7 $30,117,791.61 86 $25,600,996.25 $5,445,519.91
Jul‐22 $5,445,519.91 5 $75,001,495.75 70 $72,794,948.93 $7,652,066.73
Aug‐22 $7,652,066.73 4 $35,029,287.89 109 $33,437,711.77 $9,243,642.85
Sep‐22 $9,243,642.85 9 $30,207,449.20 114 $30,444,908.01 $9,006,184.04
Oct‐22 $9,006,184.04 4 $35,006,000.00 105 $31,721,664.67 $12,290,519.37
Nov‐22 $12,290,519.37 10 $23,711,567.49 66 $35,520,037.16 $482,049.70
Dec‐22 $482,049.70 13 $42,446,512.27 56 $42,533,743.53 $394,818.44
Jan‐23 $394,818.44 14 $26,595,081.18 50 $26,833,171.71 $156,727.91
Feb‐23 $156,727.91 15 $22,171,640.58 38 $22,323,256.39 $5,112.10

16. At times the amounts being credited and debited during a single month

amounts to movement of more than a billion dollars. For example, in July 2021, one

Signature Bank Binance Holdings account shows a starting balance of $468 million,

deposits of $1 billion, withdrawals of $1.3 billion, and an ending balance of $179

million. Incoming wires come from WorldPay and are paid out to Merit Peak,

19
Case 1:23-cv-01599-ABJ Document 21 Filed 06/07/23 Page 20 of 27

another Binance Holdings account and other assorted payments in wires ranging

from $10 million to $100 million increments.

July 2021 Binance Holdings Limited Deposits Withdrawals


Signature Bank Account

From Wallet ID:xxxx $561,043,603

From Wallet ID: xxxx $265,807,069

From WORLDPAY B.V. $169,925,973

From UAB FINANSINES PASLAUGOS CONTIS $29,999,985

To Binance Holdings Limited Silvergate Bank $689,000,000


Account

To Merit Peak Limited Silvergate Bank $569,980,000

To UAB FINANSINES PASLAUGOS CONTIS $30,000,000

To Amazon Web Services, Inc. ACCT $15,000,000

To Stifel Bank $10,877,039

Total $1,026,776,630 $1,314,857,039

17. A monthly summary of this Binance Holdings Limited account shows

the following:

Month Op Bal U$ Credits # Credits US$ Debits # Debits US$ Cl Bal US$

Mar‐20 $0.00 0 $0.00 0 $0.00 $0.00


Apr‐20 $0.00 3 $2,010,000.00 0 $0.00 $2,010,000.00
May‐20 $2,010,000.00 0 $0.00 0 $0.00 $2,010,000.00
Jun‐20 $2,010,000.00 6 $30,441.41 4 $7,192.42 $2,033,248.99
Jul‐20 $2,033,248.99 17 $1,886,088.85 0 $0.00 $3,919,337.44
Aug‐20 $3,919,337.84 20 $12,844,171.94 0 $0.00 $16,763,509.78
Sep‐20 $16,763,509.78 42 $65,278,772.49 8 $65,500,000.00 $16,542,282.27
Oct‐20 $16,542,282.27 26 $39,050,895.54 4 $30,000,100.00 $25,593,077.81
Nov‐20 $25,593,077.81 24 $61,431,540.62 3 $30,000,000.00 $57,024,618.43
Dec‐20 $57,024,618.43 25 $157,424,176.73 13 $119,600,200.00 $94,848,595.16
Jan‐21 $94,848,595.16 23 $229,631,928.69 17 $170,000,000.00 $154,480,523.85
Feb‐21 $154,480,523.85 20 $215,548,479.94 8 $120,000,000.00 $250,029,003.79
Mar‐21 $250,029,003.79 25 $290,254,504.27 6 $440,000,000.00 $100,283,508.56
Apr‐21 $100,283,508.56 24 $715,253,589.87 7 $700,000,000.00 $115,537,098.43
May‐21 $115,537,098.43 20 $984,363,749.60 11 $608,040,407.68 $491,860,440.35

20
Case 1:23-cv-01599-ABJ Document 21 Filed 06/07/23 Page 21 of 27

Month Op Bal U$ Credits # Credits US$ Debits # Debits US$ Cl Bal US$

Jun‐21 $491,860,440.35 24 $1,276,087,954.04 15 $1,300,000,000.00 $467,948,394.39


Jul‐21 $467,948,394.39 32 $1,026,776,629.74 16 $1,314,857,039.46 $179,867,984.67
Aug‐21 $179,867,984.67 20 $595,678,358.63 14 $770,736,128.84 $4,810,214.46
Sep‐21 $4,810,214.46 18 $1,547,000,000.00 24 $1,546,000,000.00 $5,810,214.46
Oct‐21 $5,810,214.46 8 $460,000,000.00 16 $455,000,000.00 $10,810,214.46
Nov‐21 $10,810,214.46 9 $290,000,000.00 14 $294,000,100.00 $6,810,114.46
Dec‐21 $6,810,114.46 11 $285,000,000.00 12 $290,000,000.00 $1,810,114.46
Jan‐22 $1,810,114.46 9 $235,000,000.00 14 $234,000,000.00 $2,810,114.46
Feb‐22 $2,810,114.46 11 $230,000,000.00 17 $228,000,000.00 $4,810,114.46
Mar‐22 $4,810,114.46 12 $325,000,000.00 26 $328,050,000.00 $1,760,114.46
Apr‐22 $1,760,114.48 12 $374,000,000.00 16 $374,200,000.00 $1,560,114.46
May‐22 $1,560,114.46 16 $1,105,359,334.17 17 $276,050,000.00 $830,869,448.63
Jun‐22 $830,869,448.63 22 $194,210,000.00 $636,659,448.63
Jul‐22 $636,659,448.63 1 $2,230.00 15 $217,700,000.00 $418,961,678.63
Aug‐22 $418,961,678.63 1 $760.00 24 $265,555,750.08 $153,406,688.55
Sep‐22 $153,406,688.55 2 $446,330,382.26 27 $345,200,000.00 $254,537,070.81

THE WIND DOWN AND TRANSFER OF FUNDS

18. On January 1, 2023, eight Binance/Zhao-owned companies had $58.7

million on deposit. During that same time frame, $840 million was deposited into,

and $899 million was withdrawn, from those accounts. At the end of March, those

accounts had a zero balance except for one account with $180,000. Between January

and March 2023, multiple Binance accounts paid Binary Technology Development

Private Limited more than $162 million in offshore wires, as summarized here:

Paying Entity Beneficiary FI - Flowbank SA


London FFIC Binary
Technology Development PTE
LTD
US$

BINANCE CAPITAL MANAGEMENT CO $46,975,166

BINANCE HOLDINGS LIMITED $45,000,000

BINANCE HOLDINGS LIMITED $37,945,943

BINANCE (AP) HOLDINGS LIMITED $29,613,892

21
Case 1:23-cv-01599-ABJ Document 21 Filed 06/07/23 Page 22 of 27

Paying Entity Beneficiary FI - Flowbank SA


London FFIC Binary
Technology Development PTE
LTD
US$

BINANCE HOLDINGS (IE) LIMITED $1,686,560

BINANCE (SERVICES) HOLDINGS $1,122,835

BINANCE INVESTMENTS CO. LTD $2,200

$162,346,596

19. As of May 27, 2023 all of these accounts have been closed or have a $0

balance.

I declare under penalty of perjury under the laws of the United States of

America that the foregoing is true and correct.

Executed on June 5, 2023 in Washington, D.C.

______________________________
Sachin Verma

22
Case 1:23-cv-01599-ABJ Document 21 Filed 06/07/23 Page 23 of 27

Attachment 1

Bank Account Activity in select Binance related accounts at Silvergate Bank and Signature Bank

Bank Entity Account Deposits # Deposits US$ Withdrawals # Withdrawals US$ First Transaction Date Last Transaction Date
Silvergate Bank BINANCE HOLDINGS LIMITED xxxxxx6709 866 $6,270,981,606 4,845 $6,270,976,494 6/13/2019 2/22/2023
Silvergate Bank BINANCE HOLDINGS LIMITED xxxxxx6717 34 $146,203,978 26 $146,203,978 6/21/2019 8/24/2020
$6,417,185,584 $6,417,180,472

Signature Bank BINANCE HOLDINGS LIMITED xxxxxx5685 464 $11,795,340,667 393 $11,513,836,918 4/27/2020 10/28/2022
Signature Bank BINANCE HOLDINGS LIMITED xxxxxx7894 31 $464,452,500 291 $463,936,859 12/17/2021 10/27/2022
$12,259,793,167 $11,977,773,777

TOTAL ‐ BINANCE HOLDINGS LIMITED $18,676,978,750 $18,394,954,249

Silvergate Bank BINANCE CAPITAL MANAGEMENT CO LTD xxxxxx1220 145 $484,131,038 2,080 $483,131,038 2/24/2020 2/22/2023

Signature Bank Binance Capital Management Co. LTD xxxxxx7217 11 $17,196,736 150 $17,196,736 8/13/2021 1/25/2023
Signature Bank Binance Capital Management Co. LTD xxxxxx7908 61 $904,981,456 308 $904,981,456 12/29/2021 3/20/2023
$922,178,192 $922,178,192

TOTAL ‐ BINANCE CAPITAL MANAGEMENT CO. LTD $1,406,309,230 $1,405,309,230

Silvergate Bank BAM MANAGEMENT US HOLDINGS INC xxxxxx7846 47 $276,818,473 30 $276,818,473 3/22/2022 2/3/2023
Silvergate Bank BAM MANAGEMENT US HOLDINGS INC xxxxxx4563 339 $260,852,762 2,801 $260,852,762 4/30/2019 2/22/2023
Silvergate Bank BAM MANAGEMENT US HOLDINGS INC xxxxxx9810 6 $9,500,000 6 $9,500,000 1/22/2020 7/20/2020
Silvergate Bank BAM MANAGEMENT US HOLDINGS INC xxxxxx7853 21 $586 83 $586 8/17/2022 2/22/2023
$547,171,821 $547,171,821

Signature Bank BAM MANAGEMENT US HOLDINGS INC xxxxxx0684 24 $336,763,392 24 $336,094,401 5/24/2022 4/4/2023
Signature Bank BAM MANAGEMENT US HOLDINGS INC xxxxxx8310 34 $13,436,798 316 $12,704,912 1/24/2023 4/5/2023
Signature Bank BAM MANAGEMENT US HOLDINGS INC xxxxxx3338 2 $453 1 $453 2/3/2023 3/30/2023
Signature Bank BAM MANAGEMENT US HOLDINGS INC xxxxxx3346 1 $92 1 $92 2/22/2023 3/30/2023
$350,200,735 $348,799,857

TOTAL ‐ BAM MANAGEMENT US HOLDINGS INC. $897,372,556 $895,971,678

Silvergate Bank BAM TRADING SERVICES INC. SEN ACCOUNT xxxxxx3432 22,629 $10,069,945,157 22,989 $10,069,945,157 7/2/2020 2/21/2023
Silvergate Bank BAM TRADING SERVICES INC. xxxxxx1295 17,886 $625,601,386 12,260 $625,601,386 8/26/2021 2/22/2023
Silvergate Bank BAM TRADING SERVICES INC. xxxxxx6245 904 $479,138,011 14,410 $479,138,011 8/26/2021 3/6/2023
Silvergate Bank BAM TRADING SERVICES INC. xxxxxx1113 979 $463,137,117 5,877 $463,137,117 12/30/2019 2/22/2023
Silvergate Bank BAM TRADING SERVICES INC. xxxxxx7416 259 $33,718,466 7 $33,718,466 1/21/2022 2/9/2023
Silvergate Bank BAM TRADING SERVICES INC. xxxxxx1377 7 $6,750,000 3 $83,192 9/22/2021 3/6/2023
Silvergate Bank BAM TRADING SERVICES INC. xxxxxx1121 2 $1,000,100 ‐ $0 12/30/2019 2/3/2023
Case 1:23-cv-01599-ABJ Document 21 Filed 06/07/23 Page 24 of 27

Silvergate Bank BAM TRADING SERVICES INC. xxxxxx3424 2 $526 4 $526 9/29/2020 2/3/2023
$11,679,290,764 $11,671,623,856

Signature Bank BAM TRADING SERVICES INC. xxxxxx5315 28 $230,931,536 382 $229,250,897 11/25/2019 4/5/2023
Signature Bank BAM TRADING SERVICES INC. xxxxxx2547 135 $191,814,339 243 $187,670,282 10/21/2022 4/5/2023
Signature Bank BAM TRADING SERVICES INC. xxxxxx2555 208 $45,404,285 4 $39,100,000 7/27/2022 4/4/2023
Signature Bank BAM TRADING SERVICES INC. xxxxxx5323 185 $30,888,393 238 $27,789,032 5/31/2022 4/4/2023
Signature Bank BAM TRADING SERVICES INC. xxxxxx5331 7 $15,139,830 5 $15,139,593 5/31/2022 4/4/2023
Signature Bank BAM TRADING SERVICES INC. xxxxxx7211 4 $6,005,270 2 $5,270 11/1/2022 4/4/2023
Signature Bank BAM TRADING SERVICES INC. (Collateral Account) xxxxxx6907 2 $1,238,101 1 $238,001 12/12/2019 4/4/2023
$521,421,755 $499,193,075

TOTAL ‐ BAM TRADING SERVICES INC. $12,200,712,519 $12,170,816,931

Silvergate Bank Merit Peak Limited xxxxxx5271 1,122 $21,947,605,072 882 $21,947,605,072 4/18/2019 12/8/2021
Silvergate Bank Merit Peak Limited xxxxxx5263 230 $287,729,139 190 $287,729,139 5/20/2019 12/7/2021
$22,235,334,211 $22,235,334,211

Signature Bank MERIT PEAK LIMITED xxxxxx3512 1 $100 1 $100 5/6/2021 2/17/2023

TOTAL ‐ MERIT PEAK LIMITED $22,235,334,311 $22,235,334,311

Silvergate Bank KEY VISION DEVELOPMENT LIMITED xxxxxx5981 7,323 $11,288,369,703 408 $11,288,369,703 9/30/2020 6/18/2021
Silvergate Bank KEY VISION DEVELOPMENT LIMITED xxxxxx6500 197,206 $2,086,776,079 43,183 $2,086,776,079 10/16/2020 7/23/2021
$13,375,145,782 $13,375,145,782

Signature Bank KEY VISION DEVELOPMENT LIMITED xxxxxx6221 512,239 $5,366,444,576 134,836 $5,366,444,576 8/10/2021 2/13/2023
Signature Bank KEY VISION DEVELOPMENT LIMITED xxxxxx9952 1 $500 ‐ $0 8/19/2020 8/19/2020
Signature Bank KEY VISION DEVELOPMENT LIMITED xxxxxx6795 9 $250,017,808 17 $250,000,000 1/4/2022 4/13/2022
$5,616,462,884 $5,616,444,576

TOTAL ‐ KEY VISION DEVELOPMENT LIMITED $18,991,608,666 $18,991,590,358

Silvergate Bank SIGMA CHAIN AG xxxxxx6683 168 493,632,676 664 493,627,065 6/13/2019 2/22/2023

Silvergate Bank BINANCE (SWITZERLAND) AG xxxxxx6667 135 $308,644,449 702 $308,644,448 6/13/2019 2/22/2023

* Deposits and withdrawals totals include data up to March 31, 2023


Case 1:23-cv-01599-ABJ Document 21 Filed 06/07/23 Page 25 of 27

Attachment 2

Select Information from Silvergate Bank Account Opening and Corporate Documents

Corporate Bank Accounts


Entity Domicile Accounts Beneficial Owner Principal Officers* Signatory*
Binance Holdings Delaware xxxxxx6709 Changpeng Zhao Guangying Chen Changpeng Zhao
Limited xxxxxx6717 (SEN) Guangying Chen
Binance Capital British Virgin xxxxxx1220 Changpeng Zhao Changpeng Zhao Changpeng Zhao
Management Islands Guangying Chen
Company Limited
BAM Management US Delaware xxxxxx7846 BAM Management Wei Zhou Wei Zhou
Holdings, Inc. xxxxxx4563 Company Limited Catherine Coley
xxxxxx9810 (SEN) Joshua Sroge
xxxxxx7853 William Plon
Brian Shroder
Jasmine Yoonjung
Lee
BAM Trading Services, Delaware xxxxxx3432 (SEN) BAM Management Guangying Chen Guangying Chen
Inc. xxxxxx1295 US Holdings, Inc. Jasmine Yoonjung
xxxxxx6245 Lee
xxxxxx1113 Brian Walker
xxxxxx7416 Shroder
xxxxxx1377 Catherine Coley
xxxxxx1121 Elaine Stone
xxxxxx3424 Joshua Sroge
William Plon
Binance Switzerland Switzerland xxxxxx6667 Changpeng Zhao Guangying Chen Changpeng Zhao
AG xxxxxx6675 (SEN) Guangying Chen
Merit Peak Limited British Virgin xxxxxx5271 (SEN) Changpeng Zhao Leslie Tam Changpeng Zhao
Islands xxxxxx5263 Vincent Kwok Guangying Chen
Guangying Chen
Sigma Chain Switzerland xxxxxx6683 Changpeng Zhao Guangying Chen Guangying Chen
xxxxxx6691 (SEN)
Key Vision Seychelles xxxxxx5981 (SEN) Changpeng Zhao Changpeng Zhao Changpeng Zhao
Development Limited xxxxxx6500 Guangying Chen Guangying Chen

* At least for one of several acocunts and for some points during the relevant period
Case 1:23-cv-01599-ABJ Document 21 Filed 06/07/23 Page 26 of 27

Attachment 3

Select Information from Signature Bank Account Opening and Corporate Documents

Corporate
Entity Domicile Accounts Beneficial Owner Principal Officers* Bank Accounts Signatory*
Binance Holdings Cayman Islands xxxxxx5685 Changpeng Zhao Guangying Chen Guangying Chen
Limited xxxxxx7894 Kaiser Ying Kit NG
xxxxxx5693
Binance Capital British Virgin xxxxxx7908 Changpeng Zhao Guangying Chen Guangying Chen
Management Islands xxxxxx7217 Kaiser Ying Kit NG
Company Limited
BAM Management US Delaware xxxxxx0684 Changpeng Zhao William Plon
Holdings, Inc. xxxxxx8310 Jasmine Lee
xxxxxx3338 Brian Shroder
xxxxxx3346
BAM Trading Services, Delaware xxxxxx5315 Changpeng Zhao Guangying Chen
Inc. xxxxxx2547 Catherine Coley
xxxxxx2555 William Plon
xxxxxx5323 Jasmine Lee
xxxxxx5331
xxxxxx7211
xxxxxx6907
Bifinity UAB (fka Lithuania xxxxxx9360 Changpeng Zhao Changpeng Zhao
Binance UAB) xxxxxx7924 Guangying Chen
xxxxxx8615 Kaiser Ying Kit NG
xxxxxx8381 Saulius Galatiltis
Merit Peak Limited British Virgin xxxxxx3512 Changpeng Zhao Guangying Chen
Islands xxxxxx3520
Key Vision Seychelles xxxxxx6221 Changpeng Zhao Guangying Chen
Development Limited xxxxxx9952
xxxxxx6795
SWIPEWALLET EU OU Estonia xxxxxx7878 Changpeng Zhao Guangying Chen
xxxxxx7886 (80%) Kaiser Ying Kit Ng
xxxxxx7319 Joselito Lizarondo
xxxxxx7327
Cyber Shaft Enterprise Virgin Islands xxxxxx7993 Changpeng Zhao Kaiser Ying Kit Ng
Limited (UK)
Binary Technology Singapore xxxxxx1441 Guangying Chen Guangying Chen
Development PTE Adrian Rhui Keong
Limited Darren Makarem
Binance Investment Seychelles xxxxxx2361 Changpeng Zhao Guangying Chen
Company Limited
Prime Link Virgin Islands xxxxxx7225 Changpeng Zhao Guangying Chen
Management Limited (UK) xxxxxx7916 Kaiser Ying Kit NG

Binance Holdings (IE) Ireland xxxxxx7139 Changpeng Zhao Kaiser Ying Kit Ng
Limited
Binance Technologies Ireland xxxxxx2030 Changpeng Zhao Guangying Chen
Limited Kaiser Ying Kit NG

Binance (Services) Ireland xxxxxx4989 Changpeng Zhao Kaiser Ying Kit Ng


Holdings Limited
Binance (AP) Holdings Ireland xxxxxx8000 Changpeng Zhao Kaiser Ying Kit Ng
Limited
Case 1:23-cv-01599-ABJ Document 21 Filed 06/07/23 Page 27 of 27

Binance Asia Services Singapore xxxxxx6693 Changpeng Zhao Guangying Chen


Pte Ltd Adrian Rhui Keong
Darren Makarem

Binance Canada Asset Canada xxxxxx9031 Changpeng Zhao Guangying Chen


Management Inc xxxxxx9325 Lawrence Trong Loung Truong
Susan Scullion
Binance Canada Canada xxxxxx9058 Changpeng Zhao Guangying Chen
Capital Markets Inc xxxxxx0912 Lawrence Trong Loung Truong
xxxxxx9333 Susan Scullion
Binance Canada Canada xxxxxx9066 Changpeng Zhao Guangying Chen
Holdings Limited xxxxxx9341 Lawrence Trong Loung Truong
Susan Scullion
Binance Canada Canada xxxxxx9368 Changpeng Zhao Guangying Chen
Limited xxxxxx9074 Lawrence Trong Loung Truong
Susan Scullion
Binance (AD) Limited UAE xxxxxx7814 Changpeng Zhao Guangying Chen
Dominic Longman
Binance FZE UAE xxxxxx8934 Changpeng Zhao Guangying Chen
Alexander Chehade
BV Investment UAE xxxxxx9795 Changpeng Zhao Guangying Chen
Management Limited Vishal Sacheendran
BWIN Private Limited Singapore xxxxxx0808 Changpeng Zhao Guangying Chen

Chaintecs Consulting Singapore xxxxxx1433 Changpeng Zhao Guangying Chen


Singapore Private Kaiser Ying Kit Ng
Limited Adrian Rhui Keong
Darren Makarem
Infozone Technologies Singapore xxxxxx1277 Changpeng Zhao Guangying Chen
Private Limited Adrian Rhui Keong
Darren Makarem

Tornado Singapore Singapore xxxxxx0350 Changpeng Zhao Guangying Chen


Technologies Private (80%) Adrian Rhui Keong
Limited Darren Makarem

BN KZ Technologies Kazakhstan xxxxxx8810 Changpeng Zhao Guangying Chen


Limited Anton Keen

Cyper Technologies Malaysia xxxxxx0378 Changpeng Zhao Guangying Chen


SDN BHD Adrian Rhui Keong
Darren Makarem

* At least for one of several acocunts and for some points during the relevant period

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