Source commentary by Liu Honglin of Mankun Blockchain Legal Services, published by TechFlow on November 9, 2026, at 16:21:55 (UTC+8). The account below reflects that article’s reporting and analysis at publication.
Offshore registration does not remove an exchange’s dependence on banks, stablecoin issuers or institutional counterparties. In Liu Honglin’s analysis, those connections give U.S. authorities and financial companies distinct routes to influence global crypto platforms: enforcement can restrict access, while investment and commercial partnerships can make compliance a condition of growth.
The distinction matters. A regulatory settlement, an equity investment and a stablecoin issuer’s freeze are different mechanisms—not evidence of a single coordinated policy. Liu’s broader argument is that their combined effect draws offshore exchanges more deeply into U.S.-linked financial infrastructure.
MEXC: pressure at the financial gateway
According to the article, the U.S. Treasury’s Financial Crimes Enforcement Network, or FinCEN, issued an order on November 6, 2026, prohibiting U.S. financial institutions from processing funds transfers involving MEXC.
The article says U.S. authorities determined that MEXC processed at least $16 billion connected to sanctions evasion, cybercrime and related activity between May 2021 and May 2026, involving Iran, North Korea and Russia. The order was to take effect on the 30th day after publication in the Federal Register.
MEXC responded that deposits, withdrawals and trading remained operational, that it was reviewing the order and that it intended to communicate with regulators. The article also describes Treasury Secretary Bessent as framing continued access to the U.S. financial system as incompatible with supporting Iran’s regime.
The leverage here runs through financial intermediaries: restrictions on U.S. institutions can affect an offshore exchange’s ability to move funds, regardless of where it is incorporated.
Binance: settlement obligations followed by commercial integration
In November 2023, Binance reached criminal and related enforcement resolutions with the U.S. Department of Justice and other authorities, agreeing to pay more than $4.3 billion. Changpeng Zhao pleaded guilty and resigned as chief executive.
The underlying matters included serving U.S. customers without fulfilling applicable anti-money-laundering obligations and processing transactions that violated U.S. sanctions rules. Under the Treasury arrangements described in the article, Binance faced five years of compliance monitoring, with access to books, records and systems and scrutiny of commitments including its exit from the U.S. market.
Liu argues that such conditions affect the operating model, not just the balance sheet: compliance functions must be able to stop revenue-generating activity.
Subsequent partnerships added other connections:
- December 2024: Binance and Circle announced a strategic partnership to expand USDC use in trading, payments and corporate treasury management. Circle would provide technical and liquidity support.
- 2025: Abu Dhabi investment firm MGX made a $2 billion minority equity investment in Binance. In May, a World Liberty Financial co-founder said the transaction would settle using that project’s USD1 stablecoin. The article notes World Liberty Financial’s ties to the Trump family.
- October 2025: Zhao received a presidential pardon from Donald Trump covering the relevant federal offenses involving him personally.
These events represent separate legal, commercial and political relationships. The personal pardon should not be conflated with Binance’s corporate settlement obligations.
OKX: a board seat and conditional access to traditional markets
The article reports that Intercontinental Exchange, the New York Stock Exchange’s parent company, announced an investment in OKX on March 5, 2026, at a $25 billion valuation. The investment amount was not disclosed, but ICE was to receive a board seat.
The announced plans connected exchange data and product distribution. ICE would license OKX spot crypto price data for U.S.-regulated futures products. Subject to relevant regulatory approvals, OKX planned to give its users access to ICE’s U.S. futures and the NYSE’s tokenized equity markets. These were plans, not an assertion that every proposed service was already available.
That relationship followed an enforcement resolution. In February 2025, Seychelles-based OKX operator Aux Cayes FinTech pleaded guilty and agreed to pay more than $504 million in penalties and forfeiture. U.S. prosecutors said the platform served U.S. customers despite policies restricting them, and that some employees helped customers submit false information to bypass identity checks. Its independent compliance consultant arrangement was to continue until at least February 2027.
For Liu, ICE’s board representation illustrates how integration can reach beyond product partnerships into governance.
Garantex: sanctions extended beyond banking access
OFAC sanctioned Garantex in April 2022. In March 2025, U.S., German and Finnish authorities seized domains and servers used by the exchange. The U.S. Justice Department also announced charges against relevant operators and disclosed the freezing of more than $26 million in related funds.
According to an August 2025 Treasury announcement cited in the article, successor platform Grinex took over part of the business, with arrangements also involving the ruble-backed A7A5 token. U.S. sanctions subsequently covered Grinex and associated people and companies.
Liu’s interpretation is that an exchange may continue finding customers outside mainstream financial networks, but maintaining infrastructure and counterparties becomes more difficult as enforcement follows successor arrangements.
On-chain assets still have issuer-level controls
The article identifies a separate control point in centralized stablecoins. On March 7, 2025, Tether said it had helped the U.S. Secret Service freeze $23 million associated with Garantex-related transactions. That figure is distinct from the Justice Department’s disclosure of more than $26 million frozen in related funds.
Tether had announced a voluntary wallet-freezing policy in December 2023 addressing activity associated with OFAC’s Specially Designated Nationals and Blocked Persons List, including freezing listed wallets.
The practical distinction is between holding a private key and having unrestricted transferability. A holder can initiate a transaction, but issuer controls in the token contract can restrict transfers from a frozen address. Moving funds on-chain therefore does not, by itself, remove dependence on centralized counterparties.
Integration is not a guarantee of customer protection
Liu also points to shifts in U.S. policy: BitMEX’s operating entity received a $100 million fine in January 2025 for Bank Secrecy Act violations, before that entity and several founders received Trump pardons in March.
His conclusion is that enforcement authorities, political decision-makers and private financial companies pursue different objectives, yet collectively shape exchanges’ access to customers, assets and funding.
For customers assessing these connections, the relevant questions remain concrete: which entity operates the exchange, what obligations constrain it, which counterparties provide financial access, and who can restrict the assets it uses? The partnerships and enforcement outcomes described in the article concern those dependencies; they do not establish exchange solvency, the sufficiency of reserves against liabilities or customers’ legal ownership rights.