Binance faces a $3 billion lawsuit related to Hamas terrorism in America.

A 284-page lawsuit was filed on November 24 in the federal court of North Dakota representing 306 American families who lost loved ones in the Hamas attacks on October 7, 2023, targeting Binance.

The lawsuit demands that Binance, former CEO Changpeng Zhao, and director Guangying “Heina” Chen pay approximately 1 billion USD, a figure that will automatically increase to 3 billion USD if the plaintiffs win the case under the Anti-Terrorism Act (.

Evidence includes on-chain analysis linking approximately 1 billion USD in cash flow to Hamas, Palestinian Islamic Jihad, Hezbollah, and the Islamic Revolutionary Guard Corps of Iran )IRGC(, along with Binance admitting to wrongdoing in 2023 for failing to report suspicious transactions related to these organizations.

The special feature of the lawsuit lies in the legal mechanism and the strong team of lawyers. Willkie Farr & Gallagher leads the group of plaintiffs, with crypto lawyer and former CFTC Chairman Christopher Giancarlo participating. Lead attorney Lee Wolosky co-heads Willkie's litigation department and has served as Ambassador under multiple administrations.

As Consensys lawyer Bill Hughes remarked on X, the emergence of this team indicates a clear strategy: ATA with its “triple compensation” mechanism could be applied to centralized exchanges when compliance failures become intentional support, rather than just a discovery lawsuit aimed at reaching a settlement.

The lawsuit is based on the ruling Raanan v. Binance in February, when a federal judge in Manhattan denied a motion to dismiss JASTA claims against Binance. Raanan paved the way for the presentation of transaction data, internal messages, and a 70-page analysis of the relationship between Binance and Iran's Nobitex exchange, which Elliptic referred to as “critical infrastructure” that helps the IRGC evade sanctions.

ATA and its differences with Twitter

The Anti-Terrorism Act allows American citizens harmed by international terrorism to seek triple damages from anyone who aids the attackers.

In 2016, JASTA added secondary liability: the plaintiff must prove that the defendant had a “general awareness” of the role in the terrorist activity and provided “significant intentional support.”

The case Twitter v. Taamneh )2023( decided by the U.S. Supreme Court ruled that merely providing “ordinary” services is insufficient; the plaintiff must demonstrate “conscious and culpable participation.” Social media platforms evade liability because their services are pervasive, and efforts at moderation reduce the likelihood of conscious complicity.

The crypto exchange is different. The lawsuit points out that the FinCEN 2023 consent order confirms that Binance “does not report transactions related to terrorist groups such as Al Qaeda, ISIS, Hamas' Al-Qassam Brigades, and Palestinian Islamic Jihad.”

The lawsuit also cites internal messages, in which a compliance employee said that the customers “came to commit crimes” and “we see it as bad but turn a blind eye.” This is the key point: from “we are just a platform” to “the defendants intentionally built infrastructure for the sanctioned group.”

Off-chain architecture and legal responsibilities

The lawsuit alleges that Binance built a platform to evade AML/KYC, prioritize VIP customers, encourage location concealment, and undermine oversight at the direction of CZ.

The centralized exchange gathers customer funds into the omnibus wallet ), recording them internally instead of on-chain. Transactions are calculated internally, only touching the public blockchain when withdrawing funds. According to the plaintiff, this structure creates a “financial system” for foreign terrorist organizations to transfer money without leaving a blockchain trace.

FinCEN 2023 noted that Binance must maintain an AML program and submit SARs, but the reporting system and staff have repeatedly failed, protecting flagged customers and encouraging “avoid international KYC.”

The lawsuit states that Binance processed approximately $7.8 billion in cash flow with the Nobitex exchange, accounting for ~70% of the crypto volume in Iran. An account linked to Hezbollah had nearly $17.8 million in transactions in less than two years, including direct cash flow from a sponsor designated by OFAC.

The plaintiff asserts that Binance knew Hamas and related groups were using the platform, but still chose profit over the obligation to combat terrorism.

If the proof of the floor architecture and VIP design incentives is aimed at supporting the punished cash flow, the plaintiffs meet the “conscious and culpable participation” standard according to Taamneh. They also accuse Binance of actively maintaining wallets, transferring money, and accessing USD liquidity, making the attacks on October 7 predictable.

Legal consequences and system

The short-term risk is not just 3 billion USD, as the investigation process will be prolonged, and Binance may cite jurisdiction reasons. The real risk is that the Raanan case and the current lawsuit serve as a template for other plaintiffs to replicate.

Even without a final ruling, the lawsuit adds pressure on banks and regulations. Binance.US previously had to suspend USD deposits when banking partners cut off fiat channels; the volume of BUSD dropped from $12 billion per day to under $1 billion by mid-2025.

The European Securities and Markets Authority warns that Binance accounts for more than half of the global crypto trading volume, creating systemic risks if legal pressure forces the exchange to scale back its operations.

Banks assess legal risk in their service decisions. ATA repeats that offshore exchanges become more expensive, driving stricter KYC and deeper blockchain analysis, increasing compliance costs.

The FinCEN 2023 agreement requires Binance to have 5 years of oversight, including real-time controls related to Iran, Syria, Lebanon, and Gaza. The dispersion of liquidity for the USDT, TRX, BTC/ETH pairs has become imperative.

Bitcoin and Ethereum ETF funds focus on USD access to regulated U.S. brokers, without AML oversight or ATA risk.

For traders who need high-frequency access or deep altcoins, the choice is clear: stay on the offshore exchange and bear the compliance costs, or switch to a DEX lacking fiat on-ramp but without centralized bottlenecks.

If the current lawsuit overcomes the motions to dismiss, many ATA/JASTA lawsuits targeting exchanges with a history of enforcement will emerge. The legal mechanism for triple damages already exists; the remaining question is the evidence and the level of support.

Willkie Farr's involvement sends a strong message: serious compliance failures can overshadow any sympathy from the industry. The plaintiff families do not necessarily have to win the lawsuit to change the flow of money; they just need to survive long enough to make every exchange with similar compliance records wonder if they are “next.”

Thạch Sanh

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