Rule2026-22962
Imposition of Special Measure Prohibiting the Transmittal of Funds Involving MEXC Global
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Published
November 10, 2026
Effective
December 10, 2026
Issuing agencies
Treasury DepartmentFinancial Crimes Enforcement Network
Abstract
FinCEN is issuing notice of an order, pursuant to section 9714(a) of the Combating Russian Money Laundering Act (Pub. L. 116- 283), as amended by section 6106(b) of the National Defense Authorization Act for Fiscal Year 2022 (Pub. L. 117-81), finding that MEXC Global--including any of its subsidiaries, branches, and offices, as well as any successor entities, operating in any jurisdiction outside of the United States--is a financial institution operating outside of the United States of primary money laundering concern in connection with Russian illicit finance and prohibiting certain transmittals of funds involving MEXC Global.
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<title>Federal Register, Volume 91 Issue 216 (Tuesday, November 10, 2026)</title>
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[Federal Register Volume 91, Number 216 (Tuesday, November 10, 2026)]
[Rules and Regulations]
[Pages 72420-72427]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2026-22962]
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DEPARTMENT OF THE TREASURY
Financial Crimes Enforcement Network
31 CFR Part 1010
Imposition of Special Measure Prohibiting the Transmittal of
Funds Involving MEXC Global
AGENCY: Financial Crimes Enforcement Network (FinCEN), Treasury.
ACTION: Order.
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SUMMARY: FinCEN is issuing notice of an order, pursuant to section
9714(a) of the Combating Russian Money Laundering Act (Pub. L. 116-
283), as amended by section 6106(b) of the National Defense
Authorization Act for Fiscal Year 2022 (Pub. L. 117-81), finding that
MEXC Global--including any of its subsidiaries, branches, and offices,
as well as any successor entities, operating in any jurisdiction
outside of the United States--is a financial institution operating
outside of the United States of primary money laundering concern in
connection with Russian illicit finance and prohibiting certain
transmittals of funds involving MEXC Global.
DATES: This action is effective December 10, 2026.
FOR FURTHER INFORMATION CONTACT: FinCEN's Regulatory Support Section by
submitting an inquiry at <a href="http://www.fincen.gov/contact">www.fincen.gov/contact</a>.
SUPPLEMENTARY INFORMATION:
I. Summary of Order
As set out in this order, MEXC Global has facilitated funds
transfers by Russia-affiliated illicit actors and in connection with
other Russia-associated illicit activities, including sanctions
evasion, and activity facilitated by Russian darknet markets. It has
also facilitated billions of dollars in transactions benefitting Iran
and its proxies, financial facilitators of the Democratic People's
Republic of Korea (DPRK), and other cybercrime actors. Accordingly,
this order (1) sets forth FinCEN's determination that MEXC Global, a
convertible virtual currency (CVC) exchanger, along with any
subsidiaries, branches, and offices of MEXC Global, and any successor
entities, operating in any jurisdiction outside of the United States
(collectively, MEXC Global) \1\ is a financial institution operating
outside of the United States of primary money laundering concern in
connection with Russian illicit finance; and (2) prohibits certain
transmittals of funds involving MEXC Global, by any covered financial
institution.
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\1\ This includes, but is not limited to, active and past MEXC
affiliated entities MEXC Global Ltd/MX Global Ltd (Seychelles); MEXC
Estonia O[Uuml] (Estonia); GIDA Technology AG (Switzerland); and MXC
Global Ltd (United Kingdom); affiliated entities formerly
incorporated in Singapore MEXC Global Foundation Ltd and MEXC
Singapore Pte Ltd; and any successor entities.
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II. Background
A. Statutory Provisions
Section 9714(a) of the Combating Russian Money Laundering Act (Pub.
L. 116-283), as amended by section 6106(b) of the National Defense
Authorization Act for Fiscal Year 2022 (Pub. L. 117-81) (section
9714),\2\ provides, in relevant part, that, if the Secretary of the
Treasury (Secretary) ``determines that reasonable grounds exist for
concluding that one or more financial institutions operating outside of
the United States . . . is of primary money laundering concern in
connection with Russian illicit finance,'' the Secretary may, ``by
order, regulation, or otherwise as permitted by law'': (1) require
domestic financial institutions and domestic financial agencies to take
one or more of the special measures described in 31 U.S.C. 5318A(b);
\3\ or (2) prohibit, or impose conditions upon, certain transmittals of
funds (as defined by the Secretary) by any domestic financial
institution or domestic financial agency (collectively, covered
financial institutions), if such transmittal of funds involves any such
financial institution. The authority of the Secretary to administer
both section 9714 and the Bank Secrecy Act (BSA) has been delegated to
FinCEN.\4\
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\2\ Section 9714 (as amended) may be found in a note to 31
U.S.C. 5318A.
\3\ See infra note [4].
\4\ Pursuant to Treasury Order 180-01, the authority of the
Secretary of the Treasury (Secretary) to administer the BSA,
including, but not limited to, 31 U.S.C. 5318A, has been delegated
to the Director of FinCEN. Treasury Order 180-01 (Jan. 14, 2020). On
August 11, 2022, and in accordance with Treasury Order 101-05 and 31
U.S.C. 321(b), Treasury's Under Secretary for Terrorism & Financial
Intelligence re-delegated to the Director of FinCEN the authority of
the Secretary under section 9714.
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Pursuant to section 9714, the Secretary may impose one or more of
six special measures. First, the Secretary may impose any of the five
special measures provided for in 31 U.S.C. 5318A(b), commonly known as
section 311 of the USA PATRIOT Act.\5\ Through special measures one
through four, the Secretary may impose additional recordkeeping,
information collection, and reporting requirements on covered financial
institutions.\6\ Through special measure five, the Secretary, in
consultation with the Secretary of State, the Attorney General, and the
Chairman of the Board of Governors of the Federal Reserve System, may
``prohibit, or impose conditions upon, the opening or maintaining in
the United States of a correspondent account or payable-through
account'' for or on behalf of a foreign banking institution, if such
correspondent account or payable-through account involves the financial
institution operating outside of the United States found to be of
primary money laundering concern.\7\ In addition
[[Page 72421]]
to the special measures set out in 31 U.S.C. 5318A, section 9714 also
provides that the Secretary may impose a special measure prohibiting,
or imposing conditions upon, certain transmittals of funds.\8\
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\5\ See 31 U.S.C. 5318A. 31 U.S.C. 5318A grants the Secretary
the authority, upon finding that reasonable grounds exist for
concluding that one or more financial institutions operating outside
of the United States is of primary money laundering concern, to
require domestic financial institutions and domestic financial
agencies to take certain ``special measures.'' Regarding the
``special measures'' that might be imposed, section 9714 references
the five special measures set out in 31 U.S.C. 5318A(b)(1)-(5).
\6\ 31 U.S.C. 5318A(b)(1)-(4).
\7\ 31 U.S.C. 5318A(b)(5).
\8\ See section 9714(a)(2).
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B. MEXC Global
MEXC Global is a CVC exchanger founded in 2018 that is incorporated
in the Seychelles, without a virtual asset service provider license \9\
and operates in and across over 170 countries \10\ through an array of
current or former subsidiaries, branches, and offices, including, but
not limited to, MEXC Global Ltd and MX Global Ltd in Seychelles; MEXC
Estonia O[Uuml] in Estonia; GIDA Technology AG in Switzerland; MXC
Global Ltd in the United Kingdom; and, formerly, Singapore-registered
MEXC Global Foundation Ltd and MEXC Singapore Pte Ltd.\11\
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\9\ See Financial Services Authority Seychelles, Press Release--
FSA Takes Enforcement Action Against MX Global Ltd for Unlicensed
Virtual Asset Services Operations (May 26, 2026), <a href="https://fsaseychelles.sc/news/press-releases/fsa-takes-enforcement-action-against-mx-global-ltd-for-unlicensed-virtual-asset-services-operations">https://fsaseychelles.sc/news/press-releases/fsa-takes-enforcement-action-against-mx-global-ltd-for-unlicensed-virtual-asset-services-operations</a>.
\10\ See CoinPedia, MEXC Overview, <a href="https://app.coinpedia.org/company/mexc/">https://app.coinpedia.org/company/mexc/</a>.
\11\ TRM Labs, MEXC Global (accessed Jun. 3, 2026). MEXC Global
was formerly known as MXC before rebranding in 2021. See MEXC
Global, ``MXC Exchange Rebranded MEXC Global, Deepening its Global
Compliance Strategy,'' Medium (June 10, 2021).
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As of June 2026, MEXC Global processed more than USD 1 billion in
daily transactions, while maintaining approximately USD 5 billion in
reserve assets. As such, MEXC Global is among the 20 largest CVC
exchangers in the world by trading volume.\12\ As of December 2025,
MEXC Global commanded approximately nine percent of the global market
share of centralized CVC exchangers by trading volume.\13\ By
comparison, the assets of the two largest centralized CVC exchangers
together represented 47.4 percent of the global market share.\14\
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\12\ See CoinPedia, Top Crypto Exchanges By Trading Volume,
<a href="https://markets.coinpedia.org/exchanges/">https://markets.coinpedia.org/exchanges/</a>.
\13\ See CoinGecko, Market Share of Centralized Crypto
Exchanges, by Trading Volume (May 2, 2026), <a href="https://www.coingecko.com/research/publications/centralized-crypto-exchanges-market-share">https://www.coingecko.com/research/publications/centralized-crypto-exchanges-market-share</a>.
\14\ See CoinGecko, Market Share of Centralized Crypto
Exchanges, by Trading Volume (May 2, 2026), <a href="https://www.coingecko.com/research/publications/centralized-crypto-exchanges-market-share">https://www.coingecko.com/research/publications/centralized-crypto-exchanges-market-share</a>.
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According to its user agreement, MEXC Global allows customers to
open user accounts for exchange between various fiat currencies and
CVC, as well as for futures trading and other services.\15\ And,
according to non-public information available to FinCEN, as of July
2026, MEXC Global offers the ability to trade in over fifty currencies,
including USD and Russian rubles (RUB), as well as access to over 3,000
different CVCs and tokenized assets.
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\15\ See MEXC, User Agreement (May 29, 2025), <a href="https://www.mexc.com/terms">https://www.mexc.com/terms</a>.
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III. Finding That MEXC Global Is a Financial Institution Operating
Outside the United States That Is of Primary Money Laundering Concern
in Connection With Russian Illicit Finance
Based on public and non-public information available to FinCEN,
FinCEN finds that reasonable grounds exist for concluding that MEXC
Global is a financial institution of primary money laundering concern
in connection with Russian illicit finance--namely, through its
facilitation of funds transfers by Russia-affiliated illicit actors and
in connection with other Russia-associated illicit activities,
including sanctions evasion, and activity facilitated by Russian
darknet markets. Moreover, FinCEN assesses that, in addition to
facilitating Russian illicit finance, MEXC Global has, in parallel,
facilitated billions of dollars in transactions benefitting Iran and
its proxies, financial facilitators of the Democratic People's Republic
of Korea (DPRK), and other cybercrime actors.
In making this finding, FinCEN has considered the relevant evidence
in light of factors identified in 31 U.S.C. 5318A(c)(2)(B), taking into
account the specific circumstances of money laundering activities in
connection with Russian illicit finance and the protection of U.S.
national security and the U.S. financial system. While FinCEN is under
no obligation pursuant to section 9714 to consider any particular
factor or set of factors when making a finding that a financial
institution operating outside of the United States is of primary money
laundering concern in connection with Russian illicit finance, it
nonetheless finds these factors instructive in guiding the analysis set
forth below.\16\
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\16\ 31 U.S.C. 5318A(c)(2)(B) provides, as relevant here, that
in making a finding that reasonable grounds exist for concluding
that a class of transactions within, or involving, a jurisdiction
outside the United States is of primary money laundering concern and
to apply one or more of special measures one through four to such a
financial institution, the Secretary shall consider such information
as the Secretary determines to be relevant, including the following
potentially relevant factors: (1) The extent to which such financial
institutions, transactions, or types of accounts are used to
facilitate or promote money laundering in or through the
jurisdiction, including any money laundering activity by organized
criminal groups, international terrorists, or entities involved in
the proliferation of weapons of mass destruction or missiles; (2)
The extent to which such institutions, transactions, or types of
accounts are used for legitimate business purposes in the
jurisdiction; and (3) The extent to which such action is sufficient
to ensure, with respect to transactions involving the jurisdiction
and institutions operating in the jurisdiction, that the purposes of
this subchapter continue to be fulfilled, and to guard against
international money laundering and other financial crimes.
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A. MEXC Global Is a Financial Institution Operating Outside the United
States
Although section 9714 does not expressly define the term
``financial institution,'' FinCEN has long defined that term to include
``money transmitters,'' including persons that accept and transmit
value that substitutes for currency, such as CVC.\17\ MEXC Global, in
operating as a CVC exchanger, is a ``money transmitter'' because it is
engaged in the transfer of funds or value that substitutes for
currency.\18\
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\17\ See, e.g., 31 U.S.C. 5312; 31 CFR 1010.100(t)(3);
1010.100(ff); 1010.605(f)(iv); FinCEN, FIN-2019-G001, Application of
FinCEN's Regulations to Certain Business Models Involving
Convertible Virtual Currencies (May 9, 2019); FinCEN, FIN-2013-G001,
Application of FinCEN's Regulations to Persons Administering,
Exchanging, or Using Virtual Currencies (Mar. 18, 2013); see also 31
U.S.C. 5312(a)(2)(J).
\18\ See 31 CFR 1010.100(t)(3), (ff)(5).
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By its own account and as described above, MEXC Global operates
through affiliates throughout the world--over time maintaining, for
instance, subsidiaries, branches, and offices in Seychelles, Hong Kong,
Singapore, Estonia, and the United Kingdom--and offers a range of money
transmitter services for individual and institutional customers in the
CVC sector in over 170 countries.\19\ Considering the services that it
provides and its places of registration, FinCEN assesses that MEXC
Global is a financial institution operating outside of the United
States within the meaning of section 9714.
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\19\ See CoinPedia, MEXC Overview, <a href="https://app.coinpedia.org/company/mexc/">https://app.coinpedia.org/company/mexc/</a>.
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Notably, to the extent that MEXC Global maintains or otherwise
operates through affiliates, subsidiaries, branches, or offices in the
United States, this order expressly excludes all such affiliates,
subsidiaries, branches, or offices from the definition of ``MEXC
Global'' and, accordingly, such affiliates, subsidiaries, branches, or
offices are outside the scope of this order.
B. Finding That MEXC Global Is a Financial Institution of Primary Money
Laundering Concern in Connection With Russian Illicit Finance
While MEXC Global's anti-money laundering and countering the
financing
[[Page 72422]]
of terrorism (AML/CFT), customer identification and verification
(sometimes referred to as ``Know Your Customer'' or ``KYC''
information), and other due diligence processes \20\ prohibit, on
paper, the opening of accounts by individuals in certain jurisdictions,
FinCEN assesses that, based on public and non-public information, MEXC
Global has facilitated transactions involving those prohibited
jurisdictions. In addition, MEXC Global has facilitated transactions
involving Russia-affiliated illicit actors and associated illicit
activities, including sanctions evasion, and activity facilitated by
Russian darknet markets, as well as transactions involving not only
U.S.-, European Union-, and United Kingdom-sanctioned persons working
on behalf of Iran and its proxies and the DPRK, but also an array of
cybercrime actors.
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\20\ While MEXC publicly claims to have certain AML/CFT
processes in place, FinCEN assesses that any such processes,
procedures, and policies, to the extent they exist, are insufficient
and have failed to prevent substantial volumes of illicit finance
involving Russia-affiliated illicit actors and associated illicit
activities, including sanctions evasion, and activity facilitated by
Russian darknet markets, as well as transactions involving not only
U.S.-, EU-, and UK-sanctioned persons working on behalf of Iran and
its proxies and the DPRK, but also an array of cybercrime actors.
See MEXC, User Agreement (May 29, 2025), <a href="https://www.mexc.com/terms">https://www.mexc.com/terms</a>.
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Notwithstanding MEXC Global's AML/CFT and other due diligence
processes, FinCEN found that MEXC Global has skirted compliance with
applicable regulatory requirements \21\--multiple nations' financial
regulators have issued notices highlighting that MEXC Global has
operated in their jurisdictions without the proper license, and in at
least one case added the CVC exchanger to a list of suspicious CVC
trading platforms \22\--and, importantly, that, between May 2021 and
May 2026, MEXC Global facilitated the movement of USD 16.7 billion in
funds connected to Russian illicit finance and other illicit
activities, including sanctions evasion and cybercrime, posing a
significant threat to the U.S. financial system. Indeed, within those
transactions, FinCEN identified numerous instances in which MEXC Global
processed transactions in violation of its own user agreement,
including direct transactions between MEXC Global and sanctioned
actors, some of whom were operating from MEXC Global's list of
prohibited jurisdictions.\23\
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\21\ MEXC Global has been the subject of regulatory scrutiny and
has been found to be operating without a license in Seychelles, Hong
Kong, and Japan. See Financial Services Authority Seychelles, Press
Release--FSA Takes Enforcement Action Against MX Global Ltd for
Unlicensed Virtual Asset Services Operations (May 26, 2026), <a href="https://fsaseychelles.sc/news/press-releases/fsa-takes-enforcement-action-against-mx-global-ltd-for-unlicensed-virtual-asset-services-operations">https://fsaseychelles.sc/news/press-releases/fsa-takes-enforcement-action-against-mx-global-ltd-for-unlicensed-virtual-asset-services-operations</a>; Hong Kong Securities and Futures Commission, SFC Warns
Public Against Unlicensed Virtual Asset Trading Platform MEXC (Mar.
15, 2024), <a href="https://apps.sfc.hk/edistributionWeb/gateway/EN/news-and-announcements/news/doc?refNo=24PR48">https://apps.sfc.hk/edistributionWeb/gateway/EN/news-and-announcements/news/doc?refNo=24PR48</a>; Japanese Financial Services
Agency, FSA Weekly Review No. 533 (Apr. 13, 2023), <a href="https://www.fsa.go.jp/en/newsletter/weekly2023/533.html">https://www.fsa.go.jp/en/newsletter/weekly2023/533.html</a>.
\22\ See Japanese Financial Services Agency, Newsletter, FSA
Weekly Review No.533 (Apr. 13, 2023), <a href="https://www.fsa.go.jp/en/newsletter/weekly2023/533.html">https://www.fsa.go.jp/en/newsletter/weekly2023/533.html</a>.
\23\ MEXC, User Agreement (May 29, 2025), <a href="https://www.mexc.com/terms">https://www.mexc.com/terms</a>.
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1. MEXC Global Is Used in Furtherance of Sanctions Evasion in
Connection With Russian Illicit Finance
MEXC Global has a history of processing CVC transfers for multiple
key actors that support Russian illicit finance. According to FinCEN
analysis of blockchain data, between May 2021 and May 2026, MEXC Global
sent or received nearly USD 1.5 billion in direct and indirect exposure
to transactions linked to Russian sanctions evasion and had significant
exposure to Russian cyber actors connected to sanctions evasion and/or
cybercrime. This includes USD 232 million in direct transactions with
entities sanctioned by the United States, the European Union (EU), and/
or the United Kingdom (UK).\24\ For example, MEXC Global transacted
with the sanctioned, Russia-backed CVC exchangers Garantex and Grinex.
Between 2019 and 2025, Garantex facilitated the movement of over USD
100 million for ransomware actors and other cybercriminals.\25\
Garantex's successor entity, Grinex, is itself a vehicle for sanctions
evasion, as it was created by Garantex employees to move funds after
Garantex was designated by OFAC for operating in Russia's financial
services sector.\26\ Following these public designations, MEXC Global
directly facilitated approximately USD 129 million in activity with
Garantex and USD 4.1 million in activity with Grinex, and MEXC Global
continued to transact with both entities as recently as June 2026.
Similarly, MEXC Global transacted with components of the Russia-based
A7 Network,\27\ a self-described sanctions-resistant payment service
provider created by the U.S.-, EU- and UK-designated Moldovan oligarch
Ilan Shor \28\ and Russia's state-owned defense bank Promsvyazbank
Public Joint Stock Company (PSB),\29\ that has evolved into a conduit
for illicit activity associated with a wide range of threat actors,
including the Islamic Revolutionary Guard Corps (IRGC) and its Quds
Force, DPRK-affiliated actors;
[[Page 72423]]
Iran-backed terrorist organizations; and cybercriminals and ransomware
actors.\30\ Significantly, OFAC has designated the founders and core
components and enablers of the A7 Network, and recently designated the
A7 Network, itself, as a significant transnational criminal
organization.\31\ Further, FinCEN recently found that transactions
involving any company operating outside of the United States that is
controlled by the A7 Network belong to a class of transactions of
primary money laundering concern in connection with Russian illicit
finance.\32\ Based on analysis of blockchain data, FinCEN assesses that
MEXC Global facilitated the transmission of at least USD 26 million
benefitting the now sanctioned A7 Network and sent or received almost
USD 200 million connected to the A7A5 token (a ruble-backed stablecoin
that operates on the Tron and Ethereum blockchains \33\ to transfer
value across A7 Network-linked actors where banking channels are
restricted or less dependable),\34\ including its issuer Old Vector LLC
and owner Ilan Shor, both sanctioned by OFAC, as well as the European
Union and the United Kingdom.\35\
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\24\ See Treasury, Press Release, Treasury Sanctions Russia-
Based Hydra, World's Largest Darknet Market, and Ransomware-Enabling
Virtual Currency Exchange Garantex (Apr. 5, 2022), <a href="https://home.treasury.gov/news/press-releases/jy0701">https://home.treasury.gov/news/press-releases/jy0701</a>; European Commission,
EU Sanctions Tracker, Grinex (Oct. 23, 2025), <a href="https://data.europa.eu/apps/eusanctionstracker/subjects/179375">https://data.europa.eu/apps/eusanctionstracker/subjects/179375</a>; European
Commission, EU Sanctions Tracker, Garantex (Feb. 24, 2025), <a href="https://data.europa.eu/apps/eusanctionstracker/subjects/172907">https://data.europa.eu/apps/eusanctionstracker/subjects/172907</a>; Foreign
Commonwealth Development Office, UK targets sanctions circumvention
and crypto networks exploited by Russia (Aug. 20, 2025), <a href="https://www.gov.uk/government/news/uk-targets-sanctions-circumvention-and-crypto-networks-exploited-by-russia">https://www.gov.uk/government/news/uk-targets-sanctions-circumvention-and-crypto-networks-exploited-by-russia</a>.
\25\ See Treasury, Press Release, Treasury Sanctions Russia-
Based Hydra, World's Largest Darknet Market, and Ransomware-Enabling
Virtual Currency Exchange Garantex (Apr. 5, 2022), <a href="https://home.treasury.gov/news/press-releases/jy0701">https://home.treasury.gov/news/press-releases/jy0701</a>.
\26\ See Treasury, Press Release, Treasury Sanctions
Cryptocurrency Exchange and Network Enabling Sanctions Evasion and
Cyber Criminals (Aug. 14, 2025), <a href="https://home.treasury.gov/news/press-releases/sb0225">https://home.treasury.gov/news/press-releases/sb0225</a>.
\27\ The core of the A7 Network is formed by three Russia-based
companies--A7 Liability Company (A7 LLC), and its subsidiaries, A71
Limited Liability Company (A71 LLC) and A7 Agent Limited Liability
Company (A7 Agent LLC)--which are jointly owned by Ilan Shor and PSB
and subject to sanctions imposed by the United States, European
Union, and United Kingdom. These entities administer the network
with and through several Russia- and Kyrgyz Republic-based persons,
including businesses and digital asset exchanges subject to
sanctions imposed by OFAC and the UK (as well as, in most cases, the
EU), including Old Vector LLC, Garantex, Grinex, Independent
Decentralized Finance Smartbank and Ecosystem (InDeFi Bank), ExVed,
and Garantex co-founder Sergey Mendeleev (Mendeleev). See FinCEN,
NPRM, Proposal of Special Measure Prohibiting the Transmittal of
Funds Regarding Transactions Involving the A7 Network's Sub-Agents,
91 FR 63208 (Oct. 5, 2026).
\28\ Ilan Shor was designated by OFAC in October 2022, pursuant
to E.O. 14024, for his involvement in Russian malign influence
operations in Moldova. He was previously arrested on money
laundering and embezzlement charges related to a 2014 theft valued
at approximately USD 1 billion from Moldovan banks. Treasury, Press
Release, Treasury Targets Corruption and the Kremlin's Malign
Influence Operations in Moldova (Oct. 26, 2022), <a href="https://home.treasury.gov/news/press-releases/jy1049">https://home.treasury.gov/news/press-releases/jy1049</a>. Ilan Shor was also
sanctioned by the United Kingdom on December 8, 2022. See UK
Foreign, Commonwealth and Development Office (FCDO), Uk Sanctions
List, <a href="https://search-uk-sanctions-list.service.gov.uk/designations/GAC0029/Individual">https://search-uk-sanctions-list.service.gov.uk/designations/GAC0029/Individual</a>.
\29\ PSB was designated by OFAC in February 2022, pursuant to
E.O. 14024, for issuing billions of dollars in financial support for
Russian defense sector companies in its role as Russia's state
defense bank. Treasury, Press Release, U.S. Treasury Imposes
Immediate Economic Costs in Response to Actions in the Donetsk and
Luhansk Regions (Feb. 22, 2022), <a href="https://home.treasury.gov/news/press-releases/jy0602">https://home.treasury.gov/news/press-releases/jy0602</a>. PSB was later redesignated in January 2025,
pursuant to E.O. 13662, for operating in the financial services
sector of the Russian Federation economy. Treasury, Press Release,
Treasury Disrupts Russia's Sanctions Evasion Schemes (Jan. 15,
2025), <a href="https://home.treasury.gov/news/press-releases/jy2785">https://home.treasury.gov/news/press-releases/jy2785</a>; see
also Open Source Centre, The Big Shor: A7 and the Illusion of
Russian Financial Innovation (2026), at. p. 9, <a href="https://static.opensourcecentre.org/assets/osc_a7_big_shor.pdf">https://static.opensourcecentre.org/assets/osc_a7_big_shor.pdf</a>.
\30\ See generally TRM Labs, ``The A7 Leaks: TRM's On-Chain
Analysis of Russia's Cryptocurrency Connections'' (June 12, 2026).
The A7 Network allows companies to transact in both fiat currency
and CVC through complex trade-based money laundering schemes using a
network of overseas sub-agents to enable sanctioned and other
illicit actors to access the international financial system. See
generally TRM Labs, The A7 Leaks: TRM's On-Chain Analysis of
Russia's Cryptocurrency Connections (June 12, 2026), <a href="https://www.trmlabs.com/resources/blog/the-a7-leaks-trms-on-chain-analysis-of-russias-cryptocurrency-connections">https://www.trmlabs.com/resources/blog/the-a7-leaks-trms-on-chain-analysis-of-russias-cryptocurrency-connections</a>.
\31\ On October 1, 2026, Treasury's Office of Foreign Assets
Control (OFAC) sanctioned the A7 Network pursuant to Executive Order
13581, as amended by Executive Order 13863, for being a foreign
person that constitutes a significant Transnational Criminal
Organization. See Treasury, Press Release, Operation Economic
Outcast Takes Unprecedented Action Against Sanctions Evasion Network
Used by Iran (Oct. 1, 2026) <a href="https://home.treasury.gov/news/press-releases/sb0644/">https://home.treasury.gov/news/press-releases/sb0644/</a>.
\32\ See FinCEN, NPRM, Proposal of Special Measure Prohibiting
the Transmittal of Funds Regarding Transactions Involving the A7
Network's Sub-Agents, 91 FR 63208 (Oct. 5, 2026); see also 31 CFR
1010.668.
\33\ The A7A5 tokens operate from smart contracts with addresses
at 0x6fA0BE17e4beA2fCfA22ef89BF8ac9aab0AB0fc9 and
TLeVfrdym8RoJreJ23dAGyfJDygRtiWKBZ. See <a href="https://etherscan.io/token/0x6fA0BE17e4beA2fCfA22ef89BF8ac9aab0AB0fc9#code">https://etherscan.io/token/0x6fA0BE17e4beA2fCfA22ef89BF8ac9aab0AB0fc9#code</a>; <a href="https://tronscan.org/token20/TLeVfrdym8RoJreJ23dAGyfJDygRtiWKBZ/code">https://tronscan.org/token20/TLeVfrdym8RoJreJ23dAGyfJDygRtiWKBZ/code</a>.
Stablecoins are a type of digital asset for which the value of the
token is tied to another asset, typically a fiat currency such as
the U.S. dollar. Stablecoins are appealing to illicit actors due to
their relative liquidity, ease of settlement, and exchange rate
stability. See Treasury, 2026 National Proliferation Financing Risk
Assessment (Mar. 2026), at p. 16, <a href="https://home.treasury.gov/system/files/246/2026-NPFRA.pdf">https://home.treasury.gov/system/files/246/2026-NPFRA.pdf</a>; see also Treasury, 2026 National Money
Laundering Risk Assessment (Mar. 2026), at pp. 52-53, <a href="https://home.treasury.gov/system/files/246/2026-NMLRA.pdf">https://home.treasury.gov/system/files/246/2026-NMLRA.pdf</a>.
\34\ See Treasury, Press Release, Treasury Sanctions
Cryptocurrency Exchange and Network Enabling Sanctions Evasion and
Cyber Criminals (Aug. 14, 2025), <a href="https://home.treasury.gov/news/press-releases/sb0225">https://home.treasury.gov/news/press-releases/sb0225</a>.
\35\ See Treasury, Press Release, Treasury Sanctions
Cryptocurrency Exchange and Network Enabling Sanctions Evasion and
Cyber Criminals (Aug. 14, 2025), <a href="https://home.treasury.gov/news/press-releases/sb0225">https://home.treasury.gov/news/press-releases/sb0225</a>; Foreign Commonwealth Development Office, UK
targets sanctions circumvention and crypto networks exploited by
Russia (Aug. 20, 2025), <a href="https://www.gov.uk/government/news/uk-targets-sanctions-circumvention-and-crypto-networks-exploited-by-russia">https://www.gov.uk/government/news/uk-targets-sanctions-circumvention-and-crypto-networks-exploited-by-russia</a>; Treasury, Press Release, Treasury Targets Corruption and the
Kremlin's Malign Influence Operations in Moldova (Oct. 26, 2022),
<a href="https://home.treasury.gov/news/press-releases/jy1049">https://home.treasury.gov/news/press-releases/jy1049</a>; UK Foreign,
Commonwealth & Development Office (FCDO), UK Sanctions List, Ilan
Shor, <a href="https://search-uk-sanctions-list.service.gov.uk/designations/GAC0029/Individual">https://search-uk-sanctions-list.service.gov.uk/designations/GAC0029/Individual</a>; European Commission, EU Sanctions Tracker, Ilan
Shor (May 30, 2023), <a href="https://data.europa.eu/apps/eusanctionstracker/subjects/153809">https://data.europa.eu/apps/eusanctionstracker/subjects/153809</a>; European Commission, EU Sanctions Tracker, Limited
Liability Company Old Vector (Oct. 23, 2025), <a href="https://data.europa.eu/apps/eusanctionstracker/subjects/179337">https://data.europa.eu/apps/eusanctionstracker/subjects/179337</a>.
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In addition, MEXC Global has repeatedly transacted with high-risk
CVC exchangers that have been sanctioned or that allegedly have no
customer identification verification requirements. For example, between
May 2018 and July 2026, MEXC Global directly facilitated transactions
cumulatively worth over USD 13 billion with at least four high-risk CVC
exchangers sanctioned by the UK for facilitating Russian sanctions
evasion and funding Russian military operations in Ukraine.\36\ Between
May 2021 and May 2026, it also processed approximately USD 2.9 billion
in direct transactions with Russian and other CVC exchangers that
allegedly do not collect customer identification and verification
information, which poses a high risk of transacting with sanctioned
entities and individuals and for otherwise engaging in illicit
activity. In addition, between September 2020 and July 2026, MEXC
Global facilitated USD 8.5 million in transactions involving Russian
darknet markets that are known to facilitate the sale of illicit goods
and services.
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\36\ See FCDO, Sanctions Notice: 26 May 2026 Regime: Russia (May
26, 2026), <a href="https://assets.publishing.service.gov.uk/media/6a2a9de71f6fa5c3377e5da7/Sanctions_Notice_Russia_26_May_2026.pdf">https://assets.publishing.service.gov.uk/media/6a2a9de71f6fa5c3377e5da7/Sanctions_Notice_Russia_26_May_2026.pdf</a>.
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Based on MEXC Global's facilitation of transactions for sanctioned
and high-risk Russian CVC exchangers, including the A7 Network, which
are widely known to move funds for sanctioned actors, cybercriminals,
and ransomware actors, FinCEN assesses that MEXC Global is a financial
institution of primary money laundering concern in connection with
Russian illicit finance.
2. MEXC Global Is Used in Furtherance of International Money Laundering
According to public and non-public information, MEXC Global also
facilitates activity in furtherance of international money laundering
in support of Iran and its proxies, financial facilitators of the DPRK,
and cybercrime.
a. MEXC Global Facilitated Transactions Involving Iran and Its Proxies
According to FinCEN analysis of blockchain information, between May
2021 and May 2026, MEXC Global facilitated the transmission of nearly
USD 2 billion connected to identified Iranian actors or known or
suspected terrorist groups, including approximately USD 1.87 billion in
transactions with exposure to Iran, a jurisdiction that is the subject
of comprehensive U.S. sanctions \37\ and special measures imposed by
FinCEN pursuant to section 311 of the USA PATRIOT Act (31 U.S.C. 5318A)
which prohibit covered financial institutions from opening or
maintaining correspondent accounts in the United States for, or on
behalf of, Iranian financial institutions.\38\ Despite the fact that
MEXC Global's user agreement states that individuals and entities
located in Iran are not allowed to use its platform, FinCEN assesses
that over USD 1 billion of this exposure took the form of direct
transactions between MEXC Global and more than 40 identified Iranian
CVC exchangers, some of which are the subject of U.S. and international
sanctions. Between May 2021 and May 2026, FinCEN assesses that MEXC
Global also facilitated the transmission of approximately USD 22
million in transactions associated with the U.S.- and EU-sanctioned
Central Bank of Iran and the U.S.-, EU-, and UK-sanctioned IRGC and its
Quds Force.\39\
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\37\ The United States maintains comprehensive sanctions on
Iran, which prohibit most transactions and activities with Iran by
U.S. persons or within the United States, unless exempt or
authorized by Treasury's Office of Foreign Assets Control (OFAC).
For more information, see OFAC, Iran Sanctions, <a href="https://ofac.treasury.gov/sanctions-programs-and-country-information/iran-sanctions">https://ofac.treasury.gov/sanctions-programs-and-country-information/iran-sanctions</a>.
\38\ See FinCEN, Imposition of Fifth Special Measure Against the
Islamic Republic of Iran as a Jurisdiction of Primary Money
Laundering Concern, 84 FR 59302 (Nov. 14, 2019); see also 31 CFR
1010.661.
\39\ See Treasury, Press Release, Treasury Sanctions Iran's
Central Bank and National Development Fund (Sept. 20, 2019), <a href="https://home.treasury.gov/news/press-releases/sm780">https://home.treasury.gov/news/press-releases/sm780</a>; European Commission,
EU Sanctions Tracker, Central Bank of Iran (Sept. 29, 2025), <a href="https://data.europa.eu/apps/eusanctionstracker/subjects/178339">https://data.europa.eu/apps/eusanctionstracker/subjects/178339</a>; Treasury,
Press Release, Treasury Designates the IRGC under Terrorism
Authority and Targets IRGC and Military Supporters under Counter-
Proliferation Authority (Oct. 13, 2017), <a href="https://home.treasury.gov/news/press-releases/sm0177">https://home.treasury.gov/news/press-releases/sm0177</a>; FCDO, UK Sanctions List, Islamic
Revolutionary Guard Corps Quds Force (Dec. 31, 2020), <a href="https://search-uk-sanctions-list.service.gov.uk/designations/INU0082/Entity">https://search-uk-sanctions-list.service.gov.uk/designations/INU0082/Entity</a>;
European Commission, EU Sanctions Tracker, IRGC (July 26, 2010),
<a href="https://data.europa.eu/apps/eusanctionstracker/subjects/5760">https://data.europa.eu/apps/eusanctionstracker/subjects/5760</a>.
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[[Page 72424]]
MEXC Global has also been exploited by multiple Iran proxy groups.
For example, FinCEN identified approximately USD 36 million in
transactions that occurred between May 2021 and May 2026 that went to
or from MEXC Global related to the Gaza-based U.S.- and UK-sanctioned
Al-Qassam Brigades and other Iran linked terrorist groups.\40\
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\40\ See, e.g., OFAC, SDGT designations (Nov. 2, 2001), <a href="https://ofac.treasury.gov/recent-actions/20011102">https://ofac.treasury.gov/recent-actions/20011102</a>; FCDO, UK Sanctions List,
Hamas including Izz al-Din al-Qassam Brigades (Dec. 31, 2020),
<a href="https://search-uk-sanctions-list.service.gov.uk/designations/CTI0031/Entity">https://search-uk-sanctions-list.service.gov.uk/designations/CTI0031/Entity</a>.
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b. MEXC Global Facilitated Transactions Involving Financial
Facilitators of the DPRK
MEXC Global has also transmitted funds on behalf of a financial
facilitator of the DPRK, a jurisdiction that, like Iran, is the subject
of comprehensive U.S. sanctions \41\ and special measures imposed by
FinCEN that prohibit covered financial institutions from opening or
maintaining correspondent accounts in the United States for, or on
behalf of, DPRK financial institutions.\42\ For instance, FinCEN
assesses that MEXC Global facilitated U.S.-sanctioned DPRK money
launderer Sim Hyon Sop's receipt of approximately USD 350,000 between
June and September 2025, more than two years after Sop had been
designated by OFAC and even though, as part of his April 2023
designation, OFAC specifically identified and sanctioned his CVC
addresses.\43\
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\41\ The United States maintains comprehensive sanctions on the
DPRK, which prohibit most transactions and activities with the DPRK
by U.S. persons or within the United States, unless exempt or
authorized by OFAC. For more information, see OFAC, North Korea
Sanctions, <a href="https://ofac.treasury.gov/sanctions-programs-and-country-information/north-korea-sanctions">https://ofac.treasury.gov/sanctions-programs-and-country-information/north-korea-sanctions</a>.
\42\ See FinCEN, Imposition of Fifth Special Measure Against
North Korea as a Jurisdiction of Primary Money Laundering Concern,
81 FR 78715 (Nov. 9, 2016); see also 31 CFR 1010.659.
\43\ See Treasury, Press Release, Treasury Targets Actors
Facilitating Illicit DPRK Financial Activity in Support of Weapons
Programs (Apr. 24, 2023), <a href="https://home.treasury.gov/news/press-releases/jy1435">https://home.treasury.gov/news/press-releases/jy1435</a>.
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c. MEXC Global Facilitated Transactions Connected to Cybercrime
Finally, MEXC Global frequently processes transactions connected to
cyber-enabled crimes, ranging from darknet marketplace activity
(including the Russian darknet marketplace activity discussed above)
and ransomware payments to scam proceeds and stolen funds. Between May
2021 and May 2026, FinCEN assesses that at least USD 1.99 billion in
funds originating from or moving to illicit cyber actors moved through
MEXC Global, an average of more than USD 1 million per day. Between
January 2022 to July 2024, MEXC Global received more than USD 37.9
million in suspected ransomware payments, with exposure to over 125
ransomware variants. MEXC Global also hosts a particularly high-use
ransomware-related deposit address, which received over USD 1.17
million during the same period.
C. The Extent to Which MEXC Global Is Used for Legitimate Business
Purposes
In reaching its finding that MEXC Global is a financial institution
operating outside the United States of primary money laundering concern
in connection with Russian illicit finance, FinCEN considered the
extent to which MEXC Global is used for legitimate business
purposes.\44\ As of June 2026, MEXC Global conducted USD 1 billion in
daily transactions, putting it among the top 20 largest CVC exchangers
in the world by trading volume. Although FinCEN does not have full
insight into the scope of MEXC Global's legitimate activities, for the
purposes of this action, FinCEN assumes that a portion of MEXC Global's
business activities are legitimate. However, FinCEN assesses that since
May 2021, MEXC Global has facilitated at least USD 16.7 billion in
likely illicit activity. Accordingly, any legitimate business conducted
by MEXC Global is outweighed by the risks posed by MEXC Global's
facilitation of illicit activity, including sanctions evasion by Russia
and Iran, and the need to protect the U.S. financial sector from the
money laundering and terrorist financing risks presented by MEXC
Global.
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\44\ See 31 U.S.C. 5318A(c)(2)(B)(ii).
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D. The Extent to Which This Action Would Guard Against International
Money Laundering and Other Financial Crimes Associated With Russian
Illicit Finance
A finding that MEXC Global is of primary money laundering concern
in connection with Russian illicit finance establishes--and
emphasizes--the significant illicit finance risks posed by MEXC
Global's provision of financial services to the Russian illicit finance
ecosystem, Russian and other darknet markets and high-risk exchanges.
Further, notwithstanding MEXC Global's ties to Russian illicit finance,
FinCEN assesses that it has facilitated over USD 1.87 billion in
transactions with exposure to Iran, including over USD 1 billion in
direct transactions between MEXC Global and Iranian CVC exchangers, as
well as transactions benefiting the DPRK and an array of illicit cyber
actors, each of which present significant risks to the U.S. financial
system. Accordingly, this order will place U.S. and foreign financial
institutions and regulators on notice to guard against those risks.
Moreover, such a finding--in combination with a prohibition on certain
transmittals of funds involving MEXC Global by covered financial
institutions--will help safeguard the U.S. financial system by severing
MEXC Global's access.
IV. Imposition of a Special Measure Prohibiting Certain Transmittals of
Funds Involving MEXC Global
Having found that MEXC Global is a financial institution operating
outside of the United States that is of primary money laundering
concern in connection with Russian illicit finance, FinCEN has
determined that the imposition of a special measure prohibiting certain
transmittals of funds involving MEXC Global is warranted.\45\ In making
this determination and assessing which special measures may be
appropriate, FinCEN has considered the relevant evidence in light of
factors identified in 31 U.S.C. 5318A(a)(4)(B). While FinCEN is under
no obligation pursuant to section 9714 to consider any particular
factor or set of factors in selecting one or more special measures, it
nonetheless finds these factors instructive in guiding the analysis set
forth below.\46\
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\45\ In connection with this action, and consistent with 31
U.S.C. 5318A(a)(4)(A), FinCEN shared a draft of this order with
staff at the following Departments and agencies with regard to the
proposed order and prohibition: the Department of Justice; the
Department of State; the Board of Governors of the Federal Reserve
System; the Federal Deposit Insurance Corporation; the Securities
and Exchange Commission; the Commodity Futures Trading Commission;
the Office of the Comptroller of the Currency; and the National
Credit Union Administration. None of the Departments or agencies
objected to the issuance of this order based on the information
provided to staff at the time.
\46\ 31 U.S.C. 5318A(a)(4)(B) provides, as relevant here, that
in selecting which special measure(s) to take, the Secretary shall
consider:
(1) whether similar action has been or is being taken by other
nations or multilateral groups;
(2) whether the imposition of any particular special measure
would create a significant competitive disadvantage, including any
undue cost or burden associated with compliance, for financial
institutions organized or licensed in the United States;
(3) the extent to which the action or the timing of the action
would have a significant adverse systemic impact on the
international payment, clearance, and settlement system, or on
legitimate business activities involving the particular
jurisdiction, institution, class of transactions, or type of
account; and
(4) the effect of the action on United States national security
and foreign policy.
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[[Page 72425]]
A. Whether the Prohibition Would Address the Money Laundering Concern
in a Manner Consistent With U.S. National Security and Foreign Policy
Interests
FinCEN has considered the effect this action will have on U.S.
national security and foreign policy, as well as the extent to which
multilateral groups or other nations have taken similar actions.\47\
FinCEN has found that, in addition to facilitating Russian illicit
financial activity and sanctions evasion schemes and serving as a high-
density transactional node for high-risk CVC exchangers, MEXC Global
plays a broader role in facilitating transactions for a diverse range
of transnational illicit actors. In particular, MEXC Global processes
transactions connected to Iranian sanctions evasion, terrorist
financing, and the laundering of scam and ransomware proceeds. FinCEN,
therefore, assesses that imposing a prohibition on certain transmittals
of funds involving MEXC Global is necessary to safeguard U.S. national
security and the U.S. financial system, as well as to serve key U.S.
national security objectives.
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\47\ See 31 U.S.C. 5318A(a)(4)(B)(i), (iv).
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In light of the quantity and volume of transactions linked to known
or suspected illicit activity processed through MEXC Global,
prohibiting certain transmittals of funds involving MEXC Global would
insulate the U.S. financial system from money laundering and other
financial crimes. In particular, prohibiting certain transmittals of
funds involving MEXC Global would further ongoing U.S. efforts to
curtail suspected Russia-associated illicit activity and financial
transactions. And, targeting illicit proceeds moved by sanctions
evasion networks, especially those with a nexus to Iran, is of highest
priority for the United States. Consequently, prohibiting certain
transmittals of funds involving MEXC Global will serve the U.S.
national security and foreign policy interests by protecting the U.S.
and international financial system from known threat actors.
Moreover, this action reinforces the expectations of AML/CFT
compliance in the financial system, highlighting the importance of
identifying and reporting suspicious activity by financial institutions
around the world. With respect to the illicit finance risks posed by
MEXC Global, that is of particular importance, as this order addresses
primary money laundering concerns that are still ongoing after multiple
jurisdictions' financial regulators have issued notices highlighting
that MEXC Global has operated in their jurisdictions without the proper
license, and in at least one case added the CVC exchanger to a list of
suspicious CVC trading platforms.\48\
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\48\ MEXC Global has been the subject of regulatory scrutiny and
has been found to be operating without a license in the Seychelles,
Hong Kong, and Japan. See Financial Services Authority Seychelles,
Press Release--FSA Takes Enforcement Action Against MX Global Ltd
for Unlicensed Virtual Asset Services Operations (May 26, 2026),
<a href="https://fsaseychelles.sc/news/press-releases/fsa-takes-enforcement-action-against-mx-global-ltd-for-unlicensed-virtual-asset-services-operations">https://fsaseychelles.sc/news/press-releases/fsa-takes-enforcement-action-against-mx-global-ltd-for-unlicensed-virtual-asset-services-operations</a>; Hong Kong Securities and Futures Commission, SFC Warns
Public Against Unlicensed Virtual Asset Trading Platform MEXC (Mar.
15, 2024), <a href="https://apps.sfc.hk/edistributionWeb/gateway/EN/news-and-announcements/news/doc?refNo=24PR48">https://apps.sfc.hk/edistributionWeb/gateway/EN/news-and-announcements/news/doc?refNo=24PR48</a>; Japanese Financial Services
Agency, FSA Weekly Review No. 533 (Apr. 13, 2023), <a href="https://www.fsa.go.jp/en/newsletter/weekly2023/533.html">https://www.fsa.go.jp/en/newsletter/weekly2023/533.html</a>.
See Japanese Financial Services Agency, Newsletter, FSA Weekly
Review No.533 (Apr. 13, 2023), <a href="https://www.fsa.go.jp/en/newsletter/weekly2023/533.html">https://www.fsa.go.jp/en/newsletter/weekly2023/533.html</a>.
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B. Whether the Prohibition of Certain Transmittals of Funds Would
Impose Undue Burdens on Legitimate Activity of MEXC Global or Third
Parties
FinCEN has considered whether prohibiting certain transmittals of
funds would create a significant competitive disadvantage, including
any undue cost or burden associated with compliance, for financial
institutions organized or licensed in the United States, as well as the
extent to which the action could have a significant adverse systemic
impact on legitimate business activities currently being conducted on
the MEXC Global platform.\49\ Indeed, while MEXC Global is used by
licit actors, the legitimate business services that it offers are
commonly offered by other regulated institutions, meaning that such
licit actors could readily find alternatives to facilitate business.
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\49\ See 31 U.S.C. 5318A(a)(4)(B)(ii), (iii).
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And, FinCEN assesses that prohibiting certain transmittals of funds
involving MEXC Global will not present a significant competitive
disadvantage for or put an undue burden on financial institutions
organized or licensed in the United States. Compliance with the
prohibition on certain transmittals of funds set out in this order
requires no tools or competencies other than those already employed by
domestic financial institutions to maintain their current AML/CFT
compliance programs. To aid covered U.S. financial institutions with
compliance, FinCEN has elected to provide within this order for the
rejection of certain transmittals of CVC that are received from or
originate at MEXC Global and outline the steps a covered financial
institution should take in such circumstances. In providing for the
rejection of CVC under certain limited circumstances, FinCEN
acknowledges that, at this time, there are technological limitations
that may limit or preclude covered financial institutions from
declining CVC transfers originating at addresses outside of their
control, and compliant institutions may find themselves in receipt of
CVC from MEXC Global despite a desire and effort to limit such
exposure.\50\ This order therefore allows covered financial
institutions the flexibility to act with discretion based on the facts
and circumstances of a particular transaction and comply with this
order, even where the originating address is no longer accessible,
where, for example, (1) CVC transfers originated from MEXC Global, but
were held for an extended period of time in an unhosted wallet, or (2)
the covered financial institution's risk mitigation procedures would
preclude returning funds to MEXC Global. Moreover, by providing for the
rejection of CVC, this order ensures that covered financial
institutions will not be subject to an undue cost or burden associated
with compliance.
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\50\ FinCEN notes that CVC payment systems are often designed to
limit the control of specific financial institutions over
transactions and to prevent rejection of funds by persons or
entities other than the sender of funds. As a result, although
covered financial institutions may institute an internal prohibition
on the sending of CVC transactions to another address or entity,
FinCEN assesses that there are few, if any, readily available ways
for covered financial institutions to ``reject'' incoming CVC
transactions (prior to receipt).
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C. Whether Any Other Reasonable Alternatives or Special Measures Would
Adequately Address the Money Laundering Concern
Before deciding to impose a prohibition on certain transmittals of
funds, FinCEN considered other available special measures.\51\ After
due
[[Page 72426]]
consideration, FinCEN has determined that a special measure prohibiting
certain transmittals of funds involving MEXC Global is the appropriate
means to adequately address the illicit finance risks posed by MEXC
Global.
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\51\ As noted in section II.A, pursuant to section 9714, these
measures include: (1) the special measures described in 31 U.S.C.
5318A(b), including the imposition of additional recordkeeping,
information collection, and reporting requirements on covered U.S.
financial institutions and/or the imposition of conditions upon the
opening or maintaining of correspondent or payable-through accounts
for or on behalf of a foreign banking institution; and (2) the
prohibition of, or imposition of conditions on, the transmittal of
funds.
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None of the special measures set out in 31 U.S.C. 5318A--special
measures one through five--would effectively address the illicit
finance threat posed by MEXC Global. Any additional recordkeeping,
information collection, or reporting requirements, as described in 31
U.S.C. 5318A(b)(1)-(4), would be insufficient to guard against the
risks posed by covered financial institutions processing transmittals
of funds involving MEXC Global. Those special measures would allow such
transfers to continue to the benefit of illicit actors connected to
Russian illicit finance, as well as Iran-related and other illicit
financial activity. Further, merely prohibiting and/or placing
conditions upon the opening or maintaining in the United States of
correspondent accounts or payable-through accounts for or on behalf of
MEXC Global, as described in 31 U.S.C. 5318A(b)(5), would be similarly
inadequate. Neither prohibiting nor imposing conditions on such
accounts would safeguard the U.S. financial system to the same degree
as prohibiting transmittals of funds, as such a special measure would
not address the movement of funds outside of a strict correspondent or
payable-through relationship, for example, through the movement of
funds outside the traditional banking relationship, which may permit
MEXC Global to access USD through indirect correspondent relationships
via other foreign financial institutions.
D. Whether the Prohibition Should Be Imposed by Order or Regulation
Pursuant to section 9714, the Secretary may impose one or more
special measures, including a prohibition on certain transmittals of
funds, ``by order, regulation or otherwise as permitted by law.'' In
determining the appropriate approach in this instance, FinCEN
considered imposing the prohibition by order or regulation, taking into
account the nature of the underlying threat, and determined that
proceeding by an order is the most appropriate course of action given
the imminent threats posed by the illicit actors whose transactions and
access to funds MEXC Global facilitates, as well as the ongoing
transactions associated with suspected activity related to Russian
illicit finance that continue to be processed through MEXC Global.
Further, FinCEN has assessed that this order will not be unduly
burdensome or impose new or unique compliance costs on financial
institutions.
A copy of this order will be published in the Federal Register. To
the extent MEXC Global or other parties have information relevant to
this order, they may submit it to FinCEN at <a href="http://www.fincen.gov/contact">www.fincen.gov/contact</a>.
V. Executive Order 14294
Section 5 of Executive Order 14294 directs that all future notices
of proposed rulemaking (NPRMs) and final rules published in the Federal
Register, the violation of which may constitute criminal regulatory
offenses, should include a statement identifying that the rule or
proposed rule is a criminal regulatory offense and the authorizing
statute.\52\ Executive Order 14294 directs agencies to draft this
statement in consultation with the Department of Justice.
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\52\ Executive Order 14294, Fighting Overcriminalization in
Federal Regulations, 90 FR 20367 (issued May 9, 2025; published May
14, 2025), <a href="https://www.federalregister.gov/executive-order/14294">https://www.federalregister.gov/executive-order/14294</a>.
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Executive Order 14294 further directs that the regulatory text of
all NPRMs and final rules with criminal consequences published in the
Federal Register after May 9, 2025, should explicitly state a mens rea
requirement for each element of a criminal regulatory offense,
accompanied by citations to the relevant provisions of the authorizing
statute.
Willful violations of any final regulations set forth in this order
may be subject to criminal penalties pursuant to 31 U.S.C. 5322 and
regulations promulgated in 31 CFR Chapter X. The statutory authority
for criminal liability requires a mens rea of willfulness as an element
pursuant to 31 U.S.C. 5322(a) and 31 U.S.C. 5322(b). FinCEN's existing
regulation, 31 CFR 1010.840, that sets out criminal penalties for
violations of regulations promulgated in 31 CFR Chapter X also includes
a mens rea of willfulness. In drafting this statement, FinCEN has
consulted with the Department of Justice.
VI. Order
A. Definitions
1. MEXC Global
The order defines ``MEXC Global,'' a Seychelles-based CVC
exchanger, to include its branches, subsidiaries, and offices operating
as a financial institution in any jurisdiction outside of the United
States, and any successor entities. For the purposes of this order, a
successor entity means any person that replaces MEXC Global, its
branches, subsidiaries, and offices by acquiring its assets, in whole
or in part, and/or carrying on the affairs of MEXC Global under a new
name. This includes, but is not limited to, any entities referenced in
this order as being branches, subsidiaries, or offices of MEXC Global
operating as a financial institution in any jurisdiction outside of the
United States. Any branches, subsidiaries, and offices of MEXC Global
located in the United States are expressly excluded from the definition
of ``MEXC Global'' for the purposes of this order.
2. Convertible Virtual Currency
The order defines ``convertible virtual currency'' (CVC) as a
medium of exchange that either has an equivalent value to currency, or
acts as a substitute for currency, but lacks legal tender status.
Bitcoin, despite having legal tender status in at least one
jurisdiction, is included as a type of CVC for the purpose of this
order.
3. Covered Financial Institution
The order defines ``covered financial institution'' as having the
same meaning as ``financial institution'' in 31 CFR 1010.100(t).
4. Transmittals of Funds
The order defines ``transmittals of funds'' as the sending and
receiving of funds, including CVC. For avoidance of doubt, for this
section, this definition of transmittal of funds applies rather than
the definition of ``transmittal of funds'' in section 1010.100(ddd).
5. Meaning of Other Terms
All terms used but not otherwise defined herein shall have the
meaning set forth in 31 CFR chapter X and 31 U.S.C. 5312.
B. Prohibition on Transmittals of Funds Involving MEXC Global
A covered financial institution is prohibited from engaging in any
transmittal of funds from or to MEXC Global.
C. Order Period
The terms of this order are effective December 10, 2026, with no
cessation date.
D. Reservation of Authority
FinCEN reserves authority to impose conditions on certain
transmittals of funds from or to MEXC Global and to grant appropriate
exemptions from the requirements of this order.
[[Page 72427]]
E. Other Obligations
Nothing in this order shall be construed to modify, impair, or
otherwise affect any requirements or obligations to which a covered
financial institution is subject pursuant to the BSA, including, but
not limited to, the filing of Suspicious Activity Reports (SARs), or
other applicable laws or regulations, such as the sanctions
administered and enforced by the U.S. Department of the Treasury's
Office of Foreign Assets Control.
F. Penalties for Noncompliance
The covered financial institution, and any of its officers,
directors, employees, and agents, may be liable for civil or criminal
penalties under 31 U.S.C. 5321 and 5322 for willfully violating this
order.
G. Validity of Order
Any judicial determination that any provision of this order is
invalid shall not affect the validity of any other provision of this
order, and each other provision shall thereafter remain in full force
and effect.
Jimmy L. Kirby,
Deputy Director, Financial Crimes Enforcement Network.
[FR Doc. 2026-22962 Filed 11-9-26; 8:45 am]
BILLING CODE 4810-02-P
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</html>Indexed from Federal Register on November 10, 2026.
This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.