In November 2025, Binance founder Changpeng 'CZ' Zhao publicly addressed what he called a 'delicate question' following a presidential pardon: whether the firm might seek a refund of the $4.3 billion fine it paid in 2023. Zhao, who no longer holds an executive role, suggested any refund would be reinvested in the United States.
The pardon added a politically charged coda to one of crypto's most consequential enforcement actions, and drew criticism from those who saw it as undercutting the accountability the settlement was meant to impose.
A test for the rule of law
Around the same time, reports indicated Binance was close to ending the DOJ monitoring clause tied to the settlement, as the administration scaled back corporate monitors. Together, the developments crystallised concerns about whether penalties on the largest crypto firms can be quietly unwound.
Precedent matters more than the individual
Clemency in a financial-crime case sets an expectation about the enforceable ceiling for future conduct, whatever the particular merits.
Compliance officers price that expectation into how firmly they can argue internally. That is the quiet cost.
