Donald Trump’s pardon of Binance founder Changpeng “CZ” Zhao removed his remaining criminal exposure while leaving intact the more than $4.3 billion that Binance has already paid to U.S. agencies.
On X, CZ treated the idea of clawing that money back as hypothetical. He replied to a post about a refund with a “delicate question” quip and added that
“IF we get any refund, we will be investing that in America anyway.”
The line landed as a meme, although the underlying issue is concrete: whether a pro-crypto White House could unwind part of the largest enforcement package ever brought against a crypto exchange, and what it would take to do that in practice.
CZ suggested that the company hasn’t asked for a refund, but he isn’t sure, stating,
“Haven’t asked yet, I think🙏.”
$4.3 billion figure isn’t a single refundable pot of money.
The starting point is that the pardon is a personal matter. CZ pleaded guilty in November 2023 to a Bank Secrecy Act violation, agreed to pay a $50 million personal penalty, and stepped down as the CEO of Binance.
He received a four-month sentence and reported to prison in April 2024, finishing his term in September. The Oct. 23 order grants him a full presidential pardon for that federal conviction. It does not name Binance, and it does not, on its face, rewrite the parallel corporate and civil settlements that produced the headline $4.3 billion figure.
Those settlements are a mosaic across at least four agencies. According to the Justice Department, Binance agreed to forfeit about $2.51 billion and pay a criminal fine of about $1.81 billion, for a total of roughly $4.316 billion in the criminal case.
The DOJ credited around $1.8 billion of that amount toward parallel resolutions with the Treasury’s Financial Crimes Enforcement Network, the Office of Foreign Assets Control, and the Commodity Futures Trading Commission, and imposed a three-year compliance monitorship.
Treasury layered additional orders on top. FinCEN issued a $3.4 billion civil monetary penalty, a five-year monitoring requirement, and a mandate that Binance’s core exchange exit the U.S. market.
OFAC added a $968.6 million sanctions settlement with its own five-year sanctions compliance monitor. The CFTC obtained a court order for $2.7 billion, split between a $1.35 billion penalty and $1.35 billion in disgorgement, plus a $150 million civil penalty against CZ personally.
In practical terms, the Binance package can be summarized as follows.
| Agency |
Type |
Amount (approx.) |
Who pays |
| DOJ |
Criminal forfeiture + fine |
$4.316 billion |
Binance corporate |
| FinCEN |
Civil penalty |
$3.4 billion |
Binance corporate |
| OFAC |
Sanctions settlement |
$968.6 million |
Binance corporate |
| CFTC |
Disgorgement + penalty |
$2.7 billion |
Binance corporate |
| CFTC |
Civil penalty |
$150 million |
CZ personally |
The numbers overlap since DOJ credited some amounts toward the Treasury and CFTC resolutions.
The broader point is that “the $4.3 billion fine” is not one pot of money waiting in a single account to be wired back.
It is a set of criminal and civil obligations across separate institutions, each with its own consent order and court record.
What a pardon can, and can’t, undo under U.S. law.
Constitutionally, the pardon power is broad for federal crimes, but it is not an all-purpose reset button.
The U.S. Constitution notes that a pardon can eliminate criminal penalties for an individual offense, including prison time and certain unpaid fines.
Yet it does not automatically vacate a conviction or retroactively nullify every consequence that flowed from it, according to the Legal Information Institute. The Justice Department distinguishes pardons from other forms of clemency, including commutations, remissions of fines, and reprieves.
A standard “full pardon” is not the same legal instrument as an explicit remission of fines.
Even when the White House does remit fines, U.S. practice focuses on amounts that are still unpaid. Legal commentary on clemency history characterizes remission as relief from outstanding criminal financial penalties rather than a mechanism for cash refunds once money has left the defendant and entered the Treasury.
That distinction goes back to nineteenth-century Supreme Court doctrine. In Knote v. United States, a 1877 case involving proceeds from seized property, the Court held that a pardon or amnesty does not entitle the recipient to reclaim funds already paid into the U.S. Treasury.
The opinion states that “moneys once in the treasury can only be withdrawn by an appropriation by law,” meaning an act of Congress, according to Justia.
Whatever the scope of the pardon power, it stops short of ordering the Treasury to cut a check with no legislative appropriation.
Modern courts have applied similar logic. After the first wave of Jan. 6 cases, some defendants who received clemency tried to recover fines or restitution that had already been collected.
Federal judges rejected those efforts, stressing that a pardon does not make the original conviction or the payment “erroneous” and that it does not create a right to reimbursement.
How CZ’s Personal Pardon Interacts With Binance’s Corporate Penalties.
Applied to Binance, the strict legal view looks straightforward. CZ’s pardon covers his personal criminal case.
It does not, by default, unwind the corporate guilty plea Binance entered in the DOJ matter, and it does not reach the civil and administrative penalties imposed by FinCEN, OFAC, and the CFTC.
Monetary obligations that have already been paid and booked into the Treasury or court-administered funds sit on the other side of the Knote line. To reverse those transfers, Congress would need to authorize the transfer of funds from the Treasury back to Binance or a related entity.
Where a Trump administration could retain room to maneuver is around the edges of what has not yet happened.
First, the president could issue additional clemency documents that expressly remit any remaining criminal fines or forfeitures still unpaid for CZ.
He could also test the theory that a corporation can be a recipient of clemency and attempt a remission order in Binance’s name, drawing on sparse historical precedent compiled in congressional research.
Second, the White House could instruct DOJ and Treasury to renegotiate or soften the existing consent orders. Court-approved settlements can be modified if both parties agree and the modification is approved by a judge.
In Binance’s case, that could involve shortening or terminating the DOJ monitorship, which is already the subject of talks about an early end.
FinCEN and OFAC could make similar moves on their five-year monitorships or adjust the “complete US exit” language that currently constrains Binance’s strategy.
Those kinds of tweaks would not generate a literal refund, yet they would have financial consequences that resemble one. A shorter monitorship and a more flexible U.S. perimeter reduce compliance overhead, freeing up capital and management bandwidth.
Agencies could also “over-credit” past payments when resolving any future issues with Binance entities, treating earlier penalties as more than sufficient under a friendlier enforcement philosophy.
How a refund could unfold under a Trump administration.
The most aggressive scenario would combine clemency with legislation. Trump could issue remissions of fines for CZ and, to the extent courts accept it, for Binance, and then support an appropriations rider that authorizes the Treasury to return a portion of the collected penalties to Binance or to a vehicle framed as a U.S. innovation fund.
Such a move would honor Knote’s requirement for an appropriation while turning the Binance resolution into a political instrument.
Any step in that direction would invite scrutiny of money flows between Binance and ventures tied to the Trump family.
That loop already exists. Abu Dhabi-backed fund MGX committed $2 billion to Binance in 2025 using USD1, a stablecoin issued by World Liberty Financial, the Trump family’s DeFi and stablecoin project.
A refund or quasi-refund of public enforcement proceeds to Binance would feed into an ecosystem in which Trump-linked crypto businesses are active counterparties.
For U.S. crypto enforcement, even the act of asking for relief would matter.
The Binance resolution served as a showcase AML and sanctions case in the prior administration, with public messaging that framed it as a model for cleaning up offshore exchanges, according to the original DOJ release and Treasury’s description of the FinCEN order as its largest virtual asset settlement, referenced in earlier coverage.
Under Trump 2.0, analysis from firms such as Galaxy Digital and the law firm Pillsbury describes a tilt toward “clarity over crackdowns,” with a greater emphasis on rulemaking and less on headline enforcement.
How DOJ and Treasury might respond to a Binance refund push.
If Binance formally pursues a refund or remission, the DOJ and Treasury would have to decide whether to publicly reiterate that the money is final or acknowledge that past deals can be reopened when political priorities change.
Other large defendants, from stablecoin issuers to U.S. exchanges, will be watching that signal when they gauge how aggressively to pursue their own cases and how to time any settlements that are still on the horizon.
Globally, a Binance refund would diverge from how prior AML and sanctions mega-cases have played out in traditional finance. Large banks that paid multibillion-dollar penalties for sanctions lapses or weak controls did not receive refunds when governments changed hands.
A reversal in Binance’s case would raise questions for partners that have treated the U.S. sanctions and AML regime as a global anchor. FATF peers and regulators in Europe and Asia could respond by tightening their own oversight of U.S. venues if they conclude that U.S. enforcement outcomes can be re-traded through domestic politics.
From CZ’s perspective, the pardon already delivers tangible benefits: freedom of movement, closure on his criminal case, and the opportunity to rebuild his public role around Binance’s next phase.
The meme version of “refund the fine” may circulate on X. The legal version would require fresh White House action, cooperation from multiple agencies, and, for any material return of cash already in the Treasury, congressional buy-in.
For now, the Binance settlement remains on the books as the crypto sector’s largest penalty, and the money is staying with the U.S. government.
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