FOIAengine: Tort Lawyers, Watchdogs Continue the Fight
The October 21 presidential pardon that wiped away Changpeng Zhao’s criminal history may have erased the felony conviction of the Binance founder, but it hasn’t freed his empire – or quieted the controversy.
Dozens of Freedom of Information Act requests – filed by news organizations, plaintiffs’ law firms, public interest groups, and crypto litigators – show that an array of watchdogs are still very much on Binance’s trail. We’ll highlight noteworthy law firm requests below. First, some background.
Billionaire Zhao, known colloquially among his friends and detractors as “CZ,” is the world’s single largest holder of crypto wealth, with estimated crypto holdings of $65 billion. His checkered past includes a 2023 guilty plea to federal charges of money laundering, for which he paid a $50 million fine and served four months in federal prison.
Zhao’s cryptocurrency exchange, Binance, is a sprawling offshore network that at its peak processed trillions of dollars in digital-asset trades, while largely avoiding traditional financial regulation. U.S. and international authorities accused Binance of becoming, in essence, a colossal money-laundering hub through which criminals laundered billions of dollars in illicit funds. Binance, and Zhao, admitted it.
The same day in November 2023 that Zhao pleaded guilty to a single money-laundering count, Binance also entered guilty pleas on federal money-laundering and other charges, and agreed to pay a $4.3 billion fine. It was the second-largest criminal fine ever, and came with burdensome federal oversight restrictions on Binance – and on Zhao. Zhao resigned as CEO and, under the terms of his plea agreement and Binance’s federal monitorship, was barred from any managerial role in the company he founded.
But after he left prison in September 2024, Zhao and his lawyers and lobbyists started working on Plan B to restore the crypto king’s reputation, and, perhaps, one day return him to operational control of Binance.
Donald Trump’s reelection two months later, and the president’s embrace of cryptocurrency, offered a hope that was realized a few weeks ago when Trump gave Zhao a full and unconditional pardon. The Justice Department posted Trump’s order of clemency here.
“Deeply grateful,” CZ replied on social media, “for today’s pardon and to President Trump for upholding America’s commitment to fairness, innovation, and justice. Will do everything we can to help make America the Capital of Crypto.”
The October 23 pardon erased Zhao’s federal felony conviction, but not Binance’s regulatory exposure. The company remains bound by multi-year monitorships and compliance obligations, while plaintiffs’ lawyers and claimants test new theories in federal court – from terrorism-financing claims in Raanan v. Binance Holdings to revived securities-fraud allegations in the Lee v. Binance class action.
Trump drew more attention to Zhao’s crimes earlier this week when the president tried to explain, in a 60 Minutes interview, why he pardoned Zhao even though government prosecutors had said Zhao caused “significant harm to U.S. national security.”
“Okay, are you ready? I don’t know who he is,” the president replied in answer to a question about Zhao. Trump added that he did not recall meeting Zhao and had “no idea who he is,” only that he had been told that Zhao was a victim of a “witch hunt” by the Biden Administration.
Trump’s pardon got us wondering: Will CZ try to make an early comeback at Binance? And who might still be standing in his way?
Those questions led us, as they often do, to PoliScio Analytics’ competitive-intelligence database FOIAengine, which tracks FOIA requests in as close to real-time as availability allows. FOIA requests to the federal government can be signals of future actions. If, as speculated, Zhao or Binance seek an early release from their federal restrictions, looking at the dozens of Binance-targeted FOIA requests in our database provides an indication of who might be standing in their way.
FOIA logs from at least four agencies – the Securities and Exchange Commission, the Commodity Futures Trading Commission, the Federal Trade Commission, and the Consumer Financial Protection Bureau – list a string of requests targeting Binance and Zhao over the past two years.
The new wave of FOIA requests is probing whether agencies like the CFPB and SEC overlooked consumer complaints about Binance’s U.S. operations. The requests point to a growing ecosystem of lawyers positioning themselves against crypto exchanges. Their FOIA requests are part legal reconnaissance, part client development.
Some FOIA requests were filed by firms representing victims of crypto fraud or terrorism; others by lawyers who are actively soliciting clients. Their filings seek agency records on everything from consumer complaints and licensing audits to internal emails between crypto regulators CFTC enforcers. Together, they form a quiet but persistent demand for more disclosure, two years after Binance’s plea deal and Zhao’s four-month prison sentence.
At the SEC, mass-tort lawyer Samantha Soefs of Nigh Goldenberg Raso & Vaughn filed a sweeping request for “documents relating to claims on behalf of victims of terrorism harmed by Binance Holdings Limited (‘Binance’), Changpeng Zhao, and certain affiliated Binance entities” from 2017 through 2023. The firm’s lawyers, who have represented victims in terrorism-financing and sanctions cases, appear to be exploring whether or how Binance’s global payment networks intersected with illicit finance. The FOIA request dovetails with civil suits accusing crypto exchanges of failing to screen transactions that may have benefited criminal groups.
A second request – this one to the CFTC – sought all emails, memos, and talking points sent to or from Jack Murphy, then a senior trial attorney and head of the agency’s Digital Asset Task Force, containing search terms such as “crypto,” “Bitcoin,” “Coinbase,” and “Binance.” The requester, unnamed in the log (customary at the CFTC), limited the search to a single workweek in July 2024 – suggesting a precise effort to reconstruct internal deliberations at a moment when the CFTC was publicly recalibrating its crypto-enforcement strategy.
Murphy has since left the agency and rejoined Akin Gump in private practice, another example of the revolving door between regulators and the industry they police.
At the FTC, New York attorney Max Dilendorf asked for “all consumer complaints submitted to the FTC and other law-enforcement and consumer-protection agencies in relation to ‘crypto exchange platforms’” since 2019. Dilendorf’s request named Coinbase, Gemini, Kraken, and Binance. Dilendorf’s firm markets itself as a Binance arbitration hub that helps clients recover lost or frozen crypto assets. His FOIA filing suggests he may be seeking evidence of systemic consumer-protection lapses that could underpin arbitration or class action claims.
And in May 2025, Galen Cheney of San Francisco’s Kronenberger Rosenfeld directed a broad FOIA to the CFPB demanding examination reports, audits, and complaint data for Binance and three other U.S. exchanges. The firm’s website highlights ongoing representations of victims of cryptocurrency theft and financial elder-abuse scams. By asking for CFPB records on “failures in securing consumer accounts” and “mishandling of consumer funds,” the request signaled that Kronenberger may be testing whether federal regulators have been asleep at the switch.
These and other FOIA requests show how Binance and Zhao remain surrounded by potential civil and regulatory exposure. Plaintiffs’ lawyers see a massive target that survived its founder’s prosecution – but still faces consumers, investors, and victims looking for restitution.
The FOIA activity also underscores how transparency has ebbed at the agencies themselves. The CFTC’s own “External Meetings” database – once a post-Dodd-Frank record of who met with commissioners and when – hasn’t been updated since 2020. Acting CFTC Chair Caroline Pham’s calendar, the subject of another FOIA request, remains unpublished since 2023. That leaves FOIA as one of the few remaining tools for reconstructing the interplay between regulators and the crypto industry during the boom-and-bust cycle that culminated in the FTX collapse and Binance’s plea.
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Next: Is the SEC mishandling FOIA requests?
John A. Jenkins, co-creator of FOIAengine, is a Washington journalist and publisher whose work has appeared in The New York Times Magazine, GQ, and elsewhere. He is a four-time recipient of the American Bar Association’s Gavel Award Certificate of Merit for his legal reporting and analysis. His most recent book is The Partisan: The Life of William Rehnquist. Jenkins founded Law Street Media in 2013. Prior to that, he was President of CQ Press, the textbook and reference publishing enterprise of Congressional Quarterly. FOIAengine is a product of PoliScio Analytics (PoliScio.com), a new venture specializing in U.S. political and governmental research, co-founded by Jenkins and Washington lawyer Randy Miller. Learn more about FOIAengine here. To review FOIA requests mentioned in this article, subscribe to FOIAengine.
Write to John A. Jenkins at JAJ@PoliScio.com.
