BitMEX

🔴 High Risk

The BitMEX case marks a pivotal moment in the enforcement of anti-money laundering (AML) regulations within the cryptocurrency industry in the United States. BitMEX, a major crypto derivatives exchange, systematically evaded U.S. regulatory oversight by failing to implement essential AML and know-your-customer (KYC) controls while actively serving U.S. customers. This egregious neglect facilitated the laundering of billions in Bitcoin deposits, amplifying risks of illicit financial activity. The resulting multi-agency crackdown, including significant fines and criminal charges against BitMEX and its founders, underscores the urgent need for stringent compliance in the rapidly evolving digital asset space and signals the U.S. government’s determination to clamp down on crypto-based money laundering.

The BitMEX case represents one of the most significant enforcement actions by U.S. authorities against a cryptocurrency exchange for money laundering and regulatory violations. BitMEX, operating through a complex offshore corporate structure, willfully ignored U.S. AML and KYC obligations required under the Bank Secrecy Act while knowingly serving U.S. customers. By failing to register as a futures commission merchant and neglecting to implement adequate compliance programs, BitMEX transformed its platform into a conduit for illicit financial flows. The exchange enabled over $11 billion in Bitcoin deposits from U.S. accounts in a system lacking transaction monitoring and customer due diligence, allowing criminals and illicit actors to exploit the anonymity of cryptocurrency markets. The U.S. Department of Justice, CFTC, and FinCEN have imposed heavy fines and criminal charges resulting in guilty pleas from BitMEX founders, signifying substantial ramifications for non-compliance in the crypto industry. The case underscores the U.S. commitment to enforcing AML laws in the digital asset space and holding firms accountable for facilitating money laundering through inadequate controls and deceptive practices.

Countries Involved

United States

Actions and charges were brought starting in October 2020, with continued developments reported through 2025.

Bitcoin (BTC), Ether (ETH), Litecoin (LTC)

Money laundering, violation of Bank Secrecy Act (BSA), operating unregistered futures commission merchant (FCM), failure to implement adequate anti-money laundering (AML) and know-your-customer (KYC) programs.

BitMEX and its affiliated companies (HDR Global Trading Limited, 100x Holdings Limited, ABS Global Trading Limited, Shine Effort Inc Limited, HDR Global Services (Bermuda) Limited), and founders Arthur Hayes, Benjamin Delo, and Samuel Reed.

N/A

BitMEX deliberately ignored U.S. AML laws by failing to implement customer identification and transaction monitoring. The platform enabled illicit crypto-based transactions by accepting funds from U.S. persons while disguising customer locations to evade regulatory oversight. Specifically, it used a complex international corporate structure, including entities in Seychelles, Bermuda, and Hong Kong, and misleading bank relationships to obscure its U.S. customer base. BitMEX offered leveraged trading in cryptocurrency derivatives without registering as required with U.S. regulators, facilitating large-scale deposits (over $11 billion in Bitcoin from U.S. accounts) without proper AML controls. This deliberate evasion of compliance transformed BitMEX into a venue for laundering illicit funds by allowing users to trade anonymously and without scrutiny, enabling the obfuscation of transaction origins and destinations.

BitMEX accepted Bitcoin deposits worth over $11 billion from at least 85,000 user accounts with U.S. ties during the relevant period. The exact laundered amount is not explicitly quantified but involves substantial transaction volumes linked to these deposits.

During the period from 2015 to 2020, BitMEX operated largely from U.S. soil while serving U.S. customers, processing trillions of dollars in digital asset derivatives transactions. It accepted funds for margin trading without conducting adequate KYC or AML checks, failing to monitor or report suspicious transactions. The platform’s operations included leveraged futures, options, and swaps on cryptocurrency without proper registration or oversight, resulting in high-volume, high-risk transactions that bypassed existing financial safeguards. This lack of oversight allowed users to move significant sums of cryptocurrency without detection, facilitating money laundering risks.

  • In October 2020, the Commodity Futures Trading Commission (CFTC) filed a civil enforcement action against BitMEX and its founders for operating an unregistered cryptocurrency derivatives trading platform and violating AML regulations.

  • In 2021, BitMEX agreed to pay up to $100 million in a settlement with U.S. regulators (FinCEN and CFTC) for failing to maintain an AML compliance program.

  • In 2022, BitMEX founders pleaded guilty to criminal Bank Secrecy Act violations.

  • In January 2025, a U.S. District Court judge in Manhattan fined BitMEX an additional $100 million for willfully neglecting AML regulations to boost revenue, coupled with two years of probation.

  • These penalties followed earlier settlements totaling approximately $110 million related to criminal and civil charges.

  • Prosecutors pursued fines exceeding $400 million, highlighting the company’s slow and inadequate remediation efforts.

  • U.S. regulators emphasized that BitMEX deliberately misled authorities and took intentional steps to evade oversight by hiding the true locations of U.S. users.

BITMEX
Case Title / Operation Name:
United States v. BitMEX and its Founders
Country(s) Involved:
United States
Platform / Exchange Used:
BitMEX
Cryptocurrency Involved:

Bitcoin (BTC), Ether (ETH), Litecoin (LTC)

Volume Laundered (USD est.):
Over $11 billion in Bitcoin deposits from U.S. accounts
Wallet Addresses / TxIDs :
N/A
Method of Laundering:

Evading AML/KYC controls, offshore corporate structuring, anonymous leveraged trading

Source of Funds:

Various illicit activities enabled by lack of AML controls in crypto trading

Associated Shell Companies:

HDR Global Trading Limited, 100x Holdings Limited, ABS Global Trading Limited, others

PEPs or Individuals Involved:

Founders: Arthur Hayes, Benjamin Delo, Samuel Reed; No PEP involvement reported

Law Enforcement / Regulatory Action:
Fined over $100 million, criminal charges filed, guilty pleas by founders, multi-agency actions
Year of Occurrence:
2020-2025
Ongoing Case:
Closed
🔴 High Risk