Binance plans to allocate more than $4 billion in the U.S. contingent on receiving a reimbursement following CZ’s pardon.

Donald Trump’s pardon of Binance founder Changpeng “CZ” Zhao eliminated his remaining criminal liabilities while preserving the over $4.3 billion that Binance has already disbursed to U.S. authorities.

On X, CZ regarded the notion of reclaiming that money as theoretical. He responded to a post regarding a refund with a “delicate question” remark and added that

“IF we get any refund, we will be investing that in America anyway.”

This statement became a meme, yet the fundamental issue is substantial: whether a pro-crypto administration could reverse part of the largest enforcement action ever taken against a crypto exchange, and what would be required to achieve that in practice.

CZ indicated that the company has not requested a refund, but he is uncertain, stating,

“Haven’t asked yet, I think.”

$4.3 billion figure isn’t a single refundable pot of money.

The initial point is that the pardon is a personal issue. CZ pleaded guilty in November 2023 to a violation of the Bank Secrecy Act, consented to a $50 million personal penalty, and resigned as CEO of Binance.

He received a four-month prison sentence and reported to incarceration in April 2024, completing his term in September. The order issued on Oct. 23 grants him a complete presidential pardon for that federal conviction. It does not mention Binance, nor does it, on its face, alter the parallel corporate and civil settlements that resulted in the notable $4.3 billion figure.

These settlements are a composite involving at least four agencies. According to the Justice Department, Binance consented to forfeit approximately $2.51 billion and pay a criminal fine of about $1.81 billion, totaling around $4.316 billion in the criminal case.

The DOJ credited about $1.8 billion of that total 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 monitoring requirement.

The Treasury added further directives. FinCEN issued a $3.4 billion civil monetary penalty, a five-year monitoring obligation, and mandated that Binance’s core exchange exit the U.S. market.

OFAC imposed a $968.6 million sanctions settlement along with its own five-year sanctions compliance monitor. The CFTC secured a court order for $2.7 billion, divided 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 figures overlap since the DOJ credited some amounts toward the Treasury and CFTC resolutions.

The broader point is that “the $4.3 billion fine” is not a single sum of money waiting in one account to be returned.

It consists of a series of criminal and civil obligations across different 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 authority is extensive for federal offenses, but it is not an all-encompassing reset mechanism.

The U.S. Constitution states that a pardon can eliminate criminal penalties for a specific offense, including incarceration and certain unpaid fines.

However, it does not automatically vacate a conviction or retroactively nullify every consequence that arose from it, according to the Legal Information Institute. The Justice Department differentiates pardons from other forms of clemency, such as commutations, remissions of fines, and reprieves.

A standard “full pardon” is not legally equivalent to an explicit remission of fines.

Even when the White House does remit fines, U.S. practice emphasizes amounts that remain unpaid. Legal commentary on clemency history describes remission as relief from outstanding criminal financial penalties rather than a mechanism for cash refunds once money has been transferred from the defendant to the Treasury.

This distinction dates back to nineteenth-century Supreme Court doctrine. In Knote v. United States, a 1877 case involving proceeds from seized property, the Court ruled 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.

Regardless of the extent of the pardon power, it does not extend to instructing the Treasury to issue a check without legislative appropriation.

Modern courts have applied similar reasoning. Following the initial wave of Jan. 6 cases, some defendants who received clemency attempted to recover fines or restitution that had already been collected.

Federal judges dismissed those attempts, emphasizing that a pardon does not render the original conviction or payment “erroneous” and does not establish a right to reimbursement.

How CZ’s Personal Pardon Interacts With Binance’s Corporate Penalties.

When applied to Binance, the strict legal perspective appears clear. CZ’s pardon pertains to his personal criminal case.

It does not, by default, reverse the corporate guilty plea Binance entered in the DOJ matter, nor does it affect the civil and administrative penalties imposed by FinCEN, OFAC, and the CFTC.

Monetary obligations that have already been settled and recorded in the Treasury or court-administered funds exist on the other side of the Knote line. To reverse those transfers, Congress would need to authorize the return of funds from the Treasury back to Binance or a related entity.

Where a Trump administration might find flexibility is in areas that have not yet occurred.

First, the president could issue additional clemency documents that explicitly remit any remaining criminal fines or forfeitures still outstanding for CZ.

He could also explore the theory that a corporation can receive clemency and attempt a remission order in Binance’s name, drawing on limited historical precedent compiled in congressional research.

Second, the White House could direct the DOJ and Treasury to renegotiate or ease the existing consent orders. Court-approved settlements can be modified if both parties agree and the modification is sanctioned by a judge.

In Binance’s situation, that could involve shortening or concluding the DOJ monitorship, which is already under discussion for an early conclusion.

FinCEN and OFAC could also take similar actions regarding their five-year monitorships or modify the “complete US exit” language that currently limits Binance’s strategy.

Such adjustments would not result in a literal refund, yet they would have financial implications that resemble one. A reduced monitorship and a more adaptable U.S. perimeter would lower compliance costs, freeing up capital and management resources.

Agencies could also “over-credit” past payments when resolving any future issues with Binance entities, treating earlier penalties as more than sufficient under a more lenient enforcement approach.

How a refund could unfold under a Trump administration.

The most ambitious scenario would merge clemency with legislation. Trump could issue remissions of fines for CZ and, to the extent courts accept it, for Binance, and then advocate for an appropriations rider that permits the Treasury to return a portion of the collected penalties to Binance or to a vehicle framed as a U.S. innovation fund.

This action would satisfy Knote’s requirement for an appropriation while transforming the Binance resolution into a political tool.

Any movement in that direction would invite scrutiny of financial flows between Binance and ventures associated with the Trump family.

This connection 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 initiative.

A refund or quasi-refund of public enforcement proceeds to Binance would contribute to an ecosystem in which Trump-linked crypto businesses are active participants.

For U.S. crypto enforcement, even the act of seeking relief would be significant.

The Binance resolution served as a prominent AML and sanctions case in the previous administration, with public messaging that framed it as a model for addressing 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, analyses from firms such as Galaxy Digital and the law firm Pillsbury indicate a shift toward “clarity over crackdowns,” with a greater focus on rulemaking and less on high-profile enforcement.

How DOJ and Treasury might respond to a Binance refund push.

If Binance formally seeks a refund or remission, the DOJ and Treasury would need to determine whether to publicly reaffirm that the money is final or acknowledge that past agreements can be revisited when political priorities shift.

Other significant defendants, from stablecoin issuers to U.S. exchanges, will be observing that signal as they assess how aggressively to pursue their own cases and how to time any settlements that are still forthcoming.

Globally, a Binance refund would contrast with how previous AML and sanctions mega-cases have unfolded in traditional finance. Major banks that incurred multibillion-dollar penalties for sanctions violations or inadequate controls did not receive refunds when administrations changed.

A reversal in Binance’s case would raise questions for partners that have viewed the U.S. sanctions and AML framework as a global standard. FATF counterparts and regulators in Europe and Asia might respond by tightening their own oversight of U.S. venues if they conclude that U.S. enforcement outcomes can be renegotiated through domestic politics.

From CZ’s viewpoint, the pardon already provides tangible advantages: freedom of movement, resolution of his criminal case, and the chance 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 necessitate new White House action, cooperation from multiple agencies, and, for any significant return of cash already in the Treasury, congressional approval.

For the time being, the Binance settlement remains recorded as the largest penalty in the crypto sector, and the funds are retained by the U.S. government.

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