A US Justice Department internal memo has warned prosecutors handling crypto cases that Binance may not continue offering the same level of assistance on customer asset freezes and seizures. According to The Information, the memo said the exchange could start imposing new conditions before complying with those requests, raising the prospect that emergency freezes may no longer be handled as quickly as they have in the past.
The memo was reportedly drafted by DOJ digital currency adviser Rachel Jones and circulated to investigators working on crypto matters. Kevin Mosley, who worked on Binance investigations in 2023, was among those briefed. Binance has pushed back on the report, saying its cooperation with US law enforcement has not changed and that no change is planned.
Abu Dhabi licensing rules are at the core of the dispute
Binance management has tied the disagreement to its licensing setup under the Abu Dhabi Global Market, or ADGM, which operates as an international financial center and free zone with its own legal and supervisory framework. The company’s position is that US authorities have misunderstood the privacy obligations attached to that structure.
Guidance from the ADGM Data Protection Office says exceptions permitting disclosure generally do not extend to requests from law enforcement bodies outside the UAE. Read strictly, that would mean overseas authorities need to use formal mutual legal assistance channels instead of receiving immediate informal support. At the same time, the same guidance allows transfers needed to establish, exercise, or defend legal claims, and it specifically cites US regulatory requests as an example. That point supports Binance’s claim that ongoing cooperation can still fit within the current rules.
Binance’s corporate communications unit said the company has no plans to alter how it communicates with US law enforcement and said cooperation with the DOJ is expanding rather than shrinking.
The issue comes after Binance’s 2023 settlement
The matter has drawn sharper attention because of the oversight structure created by Binance’s broad 2023 settlement with US authorities. In November 2023, Binance admitted to multiple federal violations, including Bank Secrecy Act breaches, unlicensed money transmission, and sanctions violations. The exchange agreed to pay more than $4.3 billion in penalties and to undergo three years of independent compliance monitoring.
That settlement also required full cooperation with US and international law enforcement. Still, in April 2025, Deputy Attorney General Todd Blanche issued a note ending enforcement-by-litigation in the digital asset sector and shutting down the National Cryptocurrency Enforcement Team, narrowing the scope of direct federal oversight.
Formal legal requests could slow asset recovery
If the approach described in the memo is put into practice, Binance could stop granting emergency freezes as a courtesy and instead require added legal procedures similar to MLAT requests. For investigators trying to recover highly mobile digital assets, even short delays can matter.
Questions about compliance have continued in parallel. The International Consortium of Investigative Journalists reported that Cambodia-linked Huione Group moved at least $408 million through Binance in November 2025. In April 2026, Senator Richard Blumenthal sought information from the DOJ and the Treasury Department over reports of more than $1 billion in transfers to Iran-linked wallets through Binance.
Scott Armstrong, a former DOJ Fraud Section official, said the proposed shift could create unnecessary barriers for law enforcement. The report notes that Binance controls roughly two-fifths of the global spot crypto market. If an exchange of that size begins requiring formal cross-border legal requests as standard practice, investigations could become slower and more complicated.