SECURITIES AND EXCHANGE COMMISSION v. BINANCE HOLDINGS LIMITED et al Document 21: Declaration

District Of Columbia District Court
Case No. 1:23-cv-01599-ABJ-ZMF
Filed June 7, 2023

DECLARATION of Sachin Verma with Attachments by SECURITIES AND EXCHANGE COMMISSION re [8] MOTION for Leave to File Excess Pages filed by SECURITIES AND EXCHANGE COMMISSION. (Scarlato, Matthew)

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Page 1 UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
__________________________________________
SECURITIES AND EXCHANGE
)
COMMISSION,
)
)
Plaintiff,
)
)
v.
)
)
BINANCE HOLDINGS LIMITED,
)
BAM TRADING SERVICES INC.,
)
BAM MANAGEMENT US HOLDINGS
)
INC., AND CHANGPENG ZHAO,
)
)
Defendants.
)
__________________________________________)
Civil Action No. _______
DECLARATION OF SACHIN VERMA
I, Sachin Verma, declare the following pursuant to Title 28, United States
Code, Section 1746:
1.
I am an active Certified Public Accountant with over 20 years of
experience. I am currently employed by the United States Securities and Exchange
Commission (“SEC”) in Washington, DC, as an Assistant Chief Accountant in the
Division of Enforcement. As part of my daily activities, I have performed numerous
reviews of financial records in connection with SEC investigations.
2.
I submit this declaration in support of the SEC’s Motion for a
Temporary Restraining Order and Preliminary Injunctions. The information set
forth herein is based upon my personal review of financial records such as bank
statements, deposits, cancelled checks, wire transfers, signature cards, and other
account documents produced to the SEC by the defendants, Silvergate Bank,

Page 2 Signature Bank, FedWire and other parties pursuant to subpoenas and document
requests (“financial records”) as of this date. My classification and summarization of
financial records in this Declaration may change based on additional information that
may be produced at a later date.1 I have cited to bates stamped document where
applicable (“record documents”).
3.
During the period from April 18, 2019 to April 5, 2023 (the “Relevant
Period”), the corporate Defendants and many other corporate entities owned by
Defendant Zhao held numerous accounts with two banks in the United States-Silvergate Bank and Signature Bank.
4.
According to their websites, both banks had proprietary networks
designed to enable their digital currency and institutional investor customers to send
U.S. dollars and euros 24 hours a day between their accounts and the accounts of
other bank customers. Silvergate promoted its SEN network as “Real-time USD and
EUR settlement between counterparties, used by some of the largest exchanges in the
world,” and “enabling near real-time transfers and immediate availability of funds.”
Signature promoted its Signet Platform as leveraging blockchain technology to allow
its commercial clients to make payments in U.S. dollars 24 hours a day, and
“transactions made on the Signet Platform settle in real time, are safe and secure and
incur no transaction fees.”
Given the volume of the documents, they are not being attached, but can made
available upon the Court’s request to the SEC’s counsel of record.
Wayback Machine for January 2023: Signet | Signature Bank (archive.org);
Wayback Machine December 2022: Silvergate Exchange Network Solutions |
Silvergate Bank | San Diego (archive.org).
1

Page 3 5.
I have reviewed account statements produced by Silvergate Bank for
the following company accounts: Binance Holdings Limited, Binance Capital
Management Co Ltd., BAM Management US Holdings Inc., BAM Trading Services
Inc., Binance (Switzerland) AG, Sigma Chain AG, Merit Peak Limited, and Key
Vision Development Limited. Many of those accounts participated in the SEN
network.
6.
I have reviewed account statements produced by Signature Bank for
the following company accounts: Binance Holdings Limited, Binance Capital
Management Inc., BAM Management US Holdings Inc., BAM Trading Services Inc.,
and Merit Peak Limited. Dozens of other Binance and non-Binance entities, all
beneficially owned by Zhao, also held accounts at Signature Bank. Many of these
bank accounts participated in the Signet network.
7.
Attachment 1 summarizes the monthly activity in the Silvergate and
Signature bank accounts of the above-mentioned companies and provides an overview
of significant amounts of money moving through these accounts during 2019-2023,
including through SEN and Signet accounts described above. Attachments 2 and summarize the corporate domicile, the beneficial owner, officers and signatories
during the relevant period.
SILVERGATE ACCOUNTS
8.
The following is a summary of account activity in the above-mentioned
accounts at Silvergate Bank during the relevant period:

Page 4 KEY VISION DEVELOPMENT LIMITED
a.
Key Vision Development Limited is a Seychelles company
beneficially owned by Zhao. The website address was identified as
“Binance.com,” the email address was identified as fiat.finance@binance.com,
and the number of employees was disclosed as “1000 (Binance).” The nature of
its business was described as a cryptocurrency exchange to allow users to
exchange digital assets. The expected funds flow activity was described as
“Deposits: Fiat is wired to bank account, transfer fee paid at this point, Fiat
will automatically convert to stablecoin (BUSD) when deposited. Withdrawals:
BUSD converted to USD and withdrawn to client’s account.”
b.
In 2020 and 2021, Key Vision deposits and withdrawals both
exceeded $13 billion (or $11 billion if internal transfers between Key Vision
accounts at Silvergate Bank are excluded). Nearly all of the funds deposited
into Key Vision accounts were transferred to an account in the name of Merit
Peak Limited. Silvergate closed Key Vision’s accounts in mid-2021.
MERIT PEAK LIMITED
c.
Relevant Merit Peak Limited financial records show that Merit
Peak Limited is a British Virgin Islands company beneficially owned by Zhao.Its email address was identified as Solutions@Binance.com, and the nature of
its business was described as OTC desk and proprietary trading of digital
assets. Silvergate closed Merit Peak’s accounts in mid-2022.

BHL-SEC-BUSD-0021710.

Page 5 d.
Between 2019 and 2021, Merit Peak accounts received $22 billion,
including approximately $11 billion from Key Vision, $7.2 billion from other
Binance entities, and $1.2 billion from BAM Trading. Merit Peak paid most of
that money - $21.6 billion - to a foreign affiliate of Paxos TrustCompany, LLC
(“Paxos”) the issuer of BUSD, a so-called stablecoin. This is summarized here:
2019-Deposits
Merit Peak Limited
2019-Withdrawals
Silvergate Bank Account
Key Vision Development Limited
$11,076,701,
Binance Entities
$7,187,710,
BAM Trading Services Inc.
$1,207,794,
Paxos Global PTE LTD
$21,557,032,
Other
$2,475,399,
$390,573,
Total
$ 21,947,605,
$21,947,605,
$287,729,
$287,729,
$22,235,334,
$22,235,334,
Silvergate Bank Account
Total
SIGMA CHAIN
e.
Sigma Chain AG is a Swiss company beneficially owned by Zhao.
Sigma Chain’s described business was as a market maker providing liquidity
to fiat exchanges. Sigma Chain’s account was closed in February 2023.
f.
Between 2019 and 2023, Sigma Chain’s account received $
million, including $184 million from Binance Holdings Limited, $145 million

SEC-SGB-E-0022457.

Page 6 from BAM Trading, $36 million from Binance Capital Management, and $million from Key Vision. During that period, Sigma Chain paid $494 million,
including $160 million to BAM Trading Services, $131 million to Binance
Holdings Limited, $21 million to Merit Peak , $2 million to Binance
(Switzerland) AG, $32 million to Guangying Chen, and $10 million to Simpson
Marine. This is summarized here:
2019-Select
Deposits
2019-2023 Select
Withdrawals
Binance Holdings Limited
$184,250,
$131,188,
BAM Trading Services Inc.
$145,000,
$160,000,
Sigma Chain Limited
Silvergate Bank Account
Binance Capital Management Co
Ltd
$36,000,
Key Vision Development Limited
$15,000,
Merit Peak
$21,000,
Guangying Chen
$32,430,
Simpson Marine (S.E.A.) Pte Ltd
$10,973,
Binance (Switzerland) AG
$2,253,
Binance Capital Management Co
Ltd
$1,000,
Other
$113,382,
$134,780,
Total
$493,632,
$493,627,
BAM MANAGEMENT US HOLDINGS INC.
g.
BAM Management US Holdings Inc., is a Delaware Company
owned by BAM Management Company Limited, all of which is beneficially

Page 7 owned by Zhao.5 The last transaction date is February 22, 2023. Between
2019 and 2023 deposits and withdrawals exceeded $500 million.
BAM TRADING SERVICES, INC.
h.
BAM Trading Services Inc., is a Delaware company owned by
BAM Management US Holdings, Inc.6 Between 2019 and 2023, deposits and
withdrawals for these accounts exceeded $11 billion. It received $4 billion from
Prime Trust, $2.4 billion from Wintermute, $760 million from Subspace
Capital LLC, $424 million from Coinbase, $380 million from KBIT Global, $million from Auros Tech Limited, $326 million from Tagomi Trading LLC, $million from Alameda Research Ltd Debtor in Possession, $160 million from
Sigma Chain, $27 million from BAM Management Holdings, and $5 million
from Merit Peak Limited. It sent $3.3 billion to Wintermute Trading, Limited,
$1.5 billion to Alameda Research Ltd Debtor in Possession, $1.2 billion to Merit
Peak Limited, $924 million to Auros Tech Limited, $683 million to Subspace
Capital LLC, $665 million to KBIT Global Limited, $145 million to Sigma
Chain.
BINANCE (SWITZERLAND) AG
i.
Binance (Switzerland) AG is a Swiss company beneficially owned
by Zhao.7 This account was closed in February 2023. Between 2019 and 2023,
deposits and withdrawals for this account exceeded $300 million, most of which
was received from Binance Holdings Limited, and paid out to a variety of
BHL-SEC-BUSD-0220886.
BTS00462320.
SEC-SGB-E-0022453.

Page 8 companies, including other Binance entities, and $20.6 million in 2022 to a
company beneficially owned by Guangying Chen, and $27.8 million to a
company beneficially owned by Zhao. This is summarized here:
2019-Select
Deposits
Binance Switzerland AG
2019-2023 Select
Withdrawals
Silvergate Bank Account
$290,950,
Binance Holdings Limited
Chaintecs Consulting Singapore
Pte.
$27,761,
Binance Europe Ltd.
$23,781,
Binary Technology Development
Pte.
$20,612,
BINANCE HOLDINGS LIMITED
j.
Binance Holdings Limited is a Cayman Islands company
beneficially owned by Zhao.8 Between 2019 and 2023, deposits and
withdrawals for these accounts exceeded $6 billion. These accounts received
approximately $5.6 billion from Binance Holdings Limited Signature Bank
account, $131 million from Sigma Chain, $95 million from Merit Peak Limited,
$5 million from Key Vision, and $17 million from Binance Capital Management
Co. Limited, and paid approximately $4.2 billion to Merit Peak, $442 million to
Binance Capital Management Company Limited, $270 million to Binance
(Switzerland) AG, $184 million to Sigma Chain, and $29 million to Key Vision.
This is summarized here:

SEC-SGB-E-0022398.

Page 9 2019-Select
Deposits
Binance Holdings Limited
2019-2023 Select
Withdrawals
Silvergate Bank Accounts
Binance Holdings Limited – Signature
Bank
$5,672,812,$131,188,
$184,250,
Merit Peak
$95,063,
$4,205,230,
Binance Capital Management Co Ltd
$17,000,
$441,811,
Sigma Chain
$270,000,
Binance (Switzerland) AG
$5,000,
Key Vision
$29,040,
BINANCE CAPITAL MANAGEMENT COMPANY LIMITED
k.
Binance Capital Management Company Limited is a British
Virgin Islands company beneficially owned by Zhao.
Between 2020 and
2023, deposits and withdrawals for these accounts exceeded $480 million,
primarily through deposits from Binance Holdings Limited, and it paid
approximately $36 million to Sigma Chain, and $17 million to Binance
Holdings.
SILVERGATE ACCOUNT CLOSURES
l.
On December 23, 2022, Silvergate informed Binance that it would
be closing accounts for Binance (Switzerland) AG, Sigma Chain, Binance
Capital Management Company, and Binance Holdings Limited, and directed
the transfer of funds to be completed by February 22, 2023, at which point the

SEC-SGB-E-0022071.

Page 10 accounts would be closed. As of March 31, 2023, all of the accounts had zero
balances.
SIGNATURE ACCOUNTS
10.
Many of the foregoing companies also held accounts at Signature Bank.
Account information from Signature Bank includes the following:
BAM MANAGEMENT US HOLDINGS INC.
a.
BAM Management US Holdings Inc., is a Delaware Company
beneficially owned by Zhao. Between 2022 and 2023, deposits and withdrawals
exceeded $350 million.
BAM TRADING SERVICES
b.
BAM Trading Services is a Delaware Company beneficially owned
by Zhao. Between 2019 and2023, deposits and withdrawals exceeded $million.
MERIT PEAK LIMITED
c.
Merit Peak bank accounts show no activity during the relevant
period.
KEY VISION DEVELOPMENT LIMITEDi
d.
Key Vision is a Seychelles company beneficially owned by Zhao.
Between 2020 and 2023, deposits and withdrawals exceeded $5.6 billion.
BINANCE CAPITAL MANAGEMENT COMPANY LIMITED
e.
Binance Capital Management is a British Virgin Islands company
beneficially owned by Zhao. Between 2021 and 2023, deposits and withdrawals
exceed $900 million. Further information is summarized as follows:

Page 11 Binance Capital Management
Company Limited
2021-Select
Deposits
2021-Select
Withdrawals
$783,000,
$50,069,
$45,564,
$9,000,
Signature Bank Accounts
Binance Holdings Limited
Swipewallet EU OU
$4,695,
Cyber Shaft Enterprises Limited
Zhao Changpeng
$62,500,
INSURED AIRCRAFT TITLE
SERVICE, LLC
$54,705,
Flowbank SA FFC Binary Technology
Development PTE Ltd
$46,975,
BINANCE HOLDINGS LIMITED
f.
Binance Holdings Limited is a Cayman company beneficially
owned by Zhao. Between 2020 and 2022, deposits and withdrawals were
approximately $12 billion. Further information is summarized as follows:
2020-Select
Deposits
Binance Holdings Limited
2020-2022 Select
Withdrawals
Signature Bank Accounts
Bifinity UAB
$6,546,897,
Worldpay B.V.
$1,859,393,
Wallet ID: xxxx
$2,807,113,
Binance Holdings Limited
$5,557,501,
Merit Peak
$2,586,980,
SWIPEWALLET EU OU
$1,237,000,

Page 12 Binance Capital Management Co. Ltd.
$714,000,
Binance Investments Company
Limited
$199,000,
Prime Link Management Limited
$105,000,
Binance Holdings (IE) Limited
$57,000,
Binance Technologies Limited
$27,000,
Binance (Services) Holdings Limited
$27,000,
Binance Technologies Limited
$20,000,
OTHER SIGNATURE BANK ACCOUNTS HELD BY ZHAO-OWNED
ENTITIES
g.
Zhao was also the beneficial owner of numerous other foreign
companies with accounts at Signature Bank. These companies are foreign
domiciled, including in Canada, UAE, Seychelles, Singapore, Lithuania,
Kazakhstan, among others. These accounts were opened by a Binance.com
employee, with Zhao as the listed beneficial owner, and Guangying Chen as the
listed signatory. Some of these companies have “Binance” in their company
name. Other companies do not bear the Binance name, but accounts were
opened in the same fashion, listing Zhao as the beneficial owner and
Guangying Chen as the signatory. Their links to Binance are consistent with a
Binance organization chart10.

BHL-SEC-BUSD-0289617.

Page 13 SIGNIFICANT TRANSFERS
11.
Binance Holdings Limited and Binance Capital Management show large
deposits and withdrawals from and to Signature accounts for some Zhao-owned
companies, and hundreds of millions of dollars have been transferred.
BIFINITY UAB TRANSFERS BILLIONS OF DOLLARS TO BINANCE
COMPANIES
a.
Bifinity UAB (fka Binance UAB) is a company located in
Lithuania and beneficially owned by Zhao. The account opening documents
state that Bifinity UAB is in the business of “provid[ing] revenue collection for
Binance operators” conducting business in “Germany, UK, Netherlands and
Switzerland.” The listed signatories on Bifinity accounts include Guangying
Chen, and the account was opened by someone from Binance.com.b.
Between 2020 and 2022, Bifinity UAB paid $6.5 billion to a
Binance Holdings Limited account. In 2021, that Binance Holdings Limited
account received $3 billion from Bifinity and $1.8 billion from WorldPay,making up the majority of deposits for the year. That money was transferred
in 2021 out of Binance Holdings Limited to Merit Peak in direct wires for $2.billion and transferred $4.8 billion to another Binance Holdings account at
Silvergate, which paid Merit Peak another $3.7 billion.
SIGB-H-0001-00000063.
WorldPay is a payments processing company that purports to provide Crypto
trading platforms with the ability to move fiat money in and out of cryptocurrency.
[https://www.protocol.com/fintech/worldpay-crypto-payments]. WorldPay paid
Binance Holdings Limited $1.76 billion in 2021.
11

Page 14 2021 Significant movements of money
between Zhao-owned entities
Select
Deposits
Select
Withdrawals
Binance Holdings Limited Signature
Bank Account
From Bifinity UAB Signature Bank Account $3,012,000,From Worldpay B.V.
$1,859,393,
To Binance Holdings Limited Silvergate
Bank Account
$4,879,000,
To Merit Peak Silvergate Account
$2,586,980,
Binance Holdings Limited Silvergate
Bank
From Binance Holdings Limited Signature
Bank
To Merit Peak Silvergate Bank Account
c.
$4,880,495,$3,735,000,
In 2022, Bifinity transferred another $3.5 billion to the same
Binance Holdings Limited account. $1.2 billion was transferred to an account
held by Swipewallet EU OU, another Zhao-owned company. Bifinity sent
another $304 million directly to Swipewallet. Swipewallet thereafter sent $1.billion in outgoing FX wires, in which USD is converted into a foreign currency
before transmitting to the beneficiary.
d.
As for the rest of the money transferred by Bifinity, Binance
Holdings Limited distributed approximately $911 million to other Binance
Holdings accounts, $697 million to Binance Capital Management, and more
than $415 million to other Zhao-owned companies. One of those Zhou-owned
entities thereafter paid $62.5 million to a personal account held by Zhao, and

Page 15 in mid-March 2023 paid almost $47 million to a company beneficially owned by
Guangying Chen. On March 14, 2023, that account wired $29,613,891.93 to an
account held by Binance AP Holdings which was then wired out to the
company owned by Guangying Chen that same day, transfers that are
summarized here:
2022 Significant movements of money
between Zhao-owned entities
Select
Deposits
Select
Withdrawals
Binance Holdings Limited Signature
Bank Account
From Bifinity UAB Signature Bank
Account
To Swipewallet Eu Ou Signature Bank
Account
$3,534,897,
$1,237,000,
To Binance Holdings Limited Accounts
‐
Binance Holdings Limited
Silvergate Bank Account
$463,000,
‐
Binance Holdings Limited
Signature Bank Account
448,000,
‐
Sub-total
$911,000,
To Binance Capital Management Co. Ltd.
Signature Bank Account
697,000,
To Zhao-owned companies
‐
Binance Investments Co. Ltd.
Signature Bank Account
162,000,
‐
Prime Link Management Limited
Signature Bank Account
$85,000,
‐
Binance Holdings (IE) Limited
Signature Bank Account
$57,000,

Page 16 2022 Significant movements of money
between Zhao-owned entities
Select
Deposits
Select
Withdrawals
‐
Binance Technologies Limited
Signature Bank Account
$27,000,
‐
Binance (Services) Holdings
Limited Signature Bank Account
$27,000,
‐
Swipewallet EU OU Signature
Bank Account
$23,400,
‐
Binance Technologies Limited
Signature Bank Account
$20,000,
‐
Other
$13,695,
‐
Sub-total
$415,095,
Swipewallet EU OU Signature Bank
Account
From Binance Holdings Limited
Signature Bank
$1,273,000,
From Bifinity UAB Silvergate Bank
Account
$304,000,
To Outgoing FX Wire
$1,575,816,
Binance Capital Management Co.
Ltd. Signature Bank Account
(includes select 2023 withdrawals
totaling $79,089,058*)
From Binance Holdings Limited
Signature Bank Account
$697,000,
To Zhao Changpeng Signature Bank
Account ($60m in 2022 and $2.5m in
2023)
$62,500,000*
To Flowbank SA FFC Binary Technology
Development PTE Ltd (a company
beneficially owned by Guangying Chen)
$46,975,166*

Page 17 2022 Significant movements of money
between Zhao-owned entities
Select
Deposits
To Binance (AP) Holding Limited
Signature Bank Account; further
transferred from Binance (AP) Holdings
Limited on March 14, 2023 to Flowbank
SA FFC FFC Binary Technology
Development PTE Ltd (a company
beneficially owned by Guangying Chen)
Select
Withdrawals
$29,613,892*
BINANCE COMMINGLED FUNDS AT MERIT PEAK FOR FURTHER TRANSFER
TO PAXOS
12.
Millions of dollars from Binance related accounts were commingled in
Merit Peak’s accounts. For example, in 2021, funds from Key Vision ($11.05 billion),
Prime Trust ($1.1 billion) (through BAM Trading) and Bifinity UAB ($6.3 billion)
(through Binance Holdings Limited) were transferred to Merit Peak and Merit Peak
transferred all of that money as part of its transfers of almost $20 billion to a foreign
affiliate of Paxos in 2021, summarized as follows:
2021 Merit Peak Select Account
Activity
Select Deposits
Select Withdrawals
Merit Peak Silvergate Bank Account
From Key Vision Development Limited
$ 11,054,700,
From Binance Holdings Limited
$ 6,321,980,
From BAM Trading Services Inc.
$1,154,753,
To Paxos Global PTE Ltd
$19,975,961,
LARGE AMOUNTS OF MONEY MOVE ACROSS BINANCE AND ZHAO-OWNED
BANK ACCOUNTS
13.
The transactions in many of the Binance or Zhao-owned company
accounts held at Silvergate Bank and Signature Bank show large amounts of money

Page 18 flowing in and out of the accounts. The large incoming credits are followed by
outgoing debits within days, with the result that the accounts maintain a relatively
much lower balance at month’s beginning and end.
14.
For example, in one Silvergate Binance Holdings 2022 account
statement, money is credited monthly from another Binance Holdings account,
accounting for most of monthly credits, and most of those credits are debited to
Binance Capital Management Limited and Binance Switzerland in interbank
transfers. In February 2022, for example, the account has a beginning balance of
$7.6M and an ending balance of $7.7M, but in that month $20 million was deposited
from another Binance Holdings account, $11M was wired to Binance Switzerland AG,
and $6M was wired to Binance Capital Management, as summarized here:
Feb 2022 Binance Holdings Limited Silvergate
Bank Account
Deposits
From Binance Holdings Limited
Withdrawals
$20,000,
To Binance (Switzerland) AG
$11,000,
To Binance Capital Management Co Ltd
$6,000,
Other
$94,
$2,944,
Total
$20,094,
$19,944,
15.
Month
This pattern of money flow repeats over months, as summarized here:
Op Bal U$
Credits #
Credits US$
Debits #
Debits US$
Cl Bal US$
Jun‐
$0.
$500,100.
$10,100.
$489,990.
Jul‐
$489,990.
$1,000,000.
$984,795.
$505,194.
Aug‐
$505,194.
$0.
$285,127.
$220,066.
Sep‐
$220,066.
$1,234,385.
$880,946.
$573,504.
Oct‐
$573,504.
$1,017,019.
$1,221,165.
$369,358.
Nov‐
$369,358.
$2,029,321.
$1,414,107.
$984,572.
Dec‐
$984,572.
$843,123.
$1,118,487.
$709,208.
Jan‐
$709,208.
$4,125,860.
$2,393,223.
$2,441,844.
Feb‐
$2,441,844.
$13,198,338.
$3,269,227.
$12,370,955.

Page 19 Month
Op Bal U$
Credits #
Credits US$
Debits #
Debits US$
Cl Bal US$
Mar‐
$12,370,955.
$38,782,117.
$38,403,462.
$12,749,610.
Apr‐
$12,749,610.
$37,816,051.
$33,842,419.
$16,723,242.
May‐
$16,723,242.
$15,676,090.
$19,467,858.
$12,931,474.
Jun‐
$12,931,474.
$40,970,092.
$20,622,814.
$33,278,752.
Jul‐
$33,278,752.
$49,078,856.
$24,545,274.
$57,812,335.
Aug‐
$57,812,335.
$96,371,547.
$93,282,559.
$60,901,323.
Sep‐
$60,901,323.
$123,915,287.
$95,746,400.
$89,070,211.
Oct‐
$89,070,211.
$55,147,022.
$20,301,712.
$123,915,520.
Nov‐
$123,915,520.
$62,021,156.
$81,150,012.
$104,786,665.
Dec‐
$104,786,665.
$91,943,354.
$129,090,458.
$67,639,560.
Jan‐
$67,639,560.
$183,316,090.
$182,693,697.
$68,261,953.
Feb‐
$68,261,953.
$156,404,925.
$174,525,739.
$50,141,140.
Mar‐
$50,141,140.
$445,542,017.
$390,911,068.
$104,772,089.
Apr‐
$104,772,089.
$730,177,804.
$727,463,722.
$107,486,170.
May‐
$107,486,170.
$607,146,622.
$699,651,009.
$14,981,784.
Jun‐
$14,981,784.
$1,345,148,277.
$1,356,483,954.
$3,646,107.
Jul‐
$3,646,107.
$689,091,808.
$653,516,941.
$39,220,974.
Aug‐
$39,220,974.
$201,614,930.
$194,182,505.
$46,653,399.
Sep‐
$46,653,399.
$131,746,373.
$162,680,683.
$15,719,089.
Oct‐
$15,719,089.
$182,695,791.
$176,397,036.
$22,017,844.$14,189,579.
Nov‐
$22,017,844.
$170,671,158.
$178,499,424.
Dec‐
$14,189,579.
$213,074,672.
$220,832,010.
$6,432,241.
Jan‐
$6,432,241.
$125,131,745.
$123,952,326.
$7,611,660.
Feb‐
$7,611,660.
$20,094,477.
$19,944,633.
$7,761,505.
Mar‐
$7,761,505.
$63,055,614.
$68,472,212.
$2,344,907.
Apr‐
$2,344,907.
$30,082,889.
$26,153,168.
$6,274,628.
May‐
$6,274,628.
$20,029,852.
$25,375,756.
$928,724.
Jun‐
$928,724.
$30,117,791.
$25,600,996.
$5,445,519.
Jul‐
$5,445,519.
$75,001,495.
$72,794,948.
$7,652,066.
Aug‐
$7,652,066.
$35,029,287.
$33,437,711.
$9,243,642.
Sep‐
$9,243,642.
$30,207,449.
$30,444,908.
$9,006,184.
Oct‐
$9,006,184.
$35,006,000.
$31,721,664.
$12,290,519.
Nov‐
$12,290,519.
$23,711,567.
$35,520,037.
$482,049.
Dec‐
$482,049.
$42,446,512.
$42,533,743.
$394,818.
Jan‐
$394,818.
$26,595,081.
$26,833,171.
$156,727.
Feb‐
$156,727.
$22,171,640.
$22,323,256.
$5,112.
16.
At times the amounts being credited and debited during a single month
amounts to movement of more than a billion dollars. For example, in July 2021, one
Signature Bank Binance Holdings account shows a starting balance of $468 million,
deposits of $1 billion, withdrawals of $1.3 billion, and an ending balance of $million. Incoming wires come from WorldPay and are paid out to Merit Peak,

Page 20 another Binance Holdings account and other assorted payments in wires ranging
from $10 million to $100 million increments.
July 2021 Binance Holdings Limited
Signature Bank Account
Deposits
From Wallet ID:xxxx
$561,043,
From Wallet ID: xxxx
$265,807,
From WORLDPAY B.V.
$169,925,
Withdrawals
$29,999,
From UAB FINANSINES PASLAUGOS CONTIS
To Binance Holdings Limited Silvergate Bank
Account
$689,000,
To Merit Peak Limited Silvergate Bank
$569,980,
To UAB FINANSINES PASLAUGOS CONTIS
$30,000,
To Amazon Web Services, Inc. ACCT
$15,000,
To Stifel Bank
$10,877,$1,026,776,
Total
17.
$1,314,857,
A monthly summary of this Binance Holdings Limited account shows
the following:
Month
Op Bal U$
Credits #
Credits US$
Debits #
Debits US$
Cl Bal US$
Mar‐
$0.
$0.
$0.
$0.
Apr‐
$0.
$2,010,000.
$0.
$2,010,000.
May‐
$2,010,000.
$0.
$0.
$2,010,000.
Jun‐
$2,010,000.
$30,441.
$7,192.
$2,033,248.
Jul‐
$2,033,248.
$1,886,088.
$0.
$3,919,337.
Aug‐
$3,919,337.
$12,844,171.
$0.
$16,763,509.
Sep‐
$16,763,509.
$65,278,772.
$65,500,000.
$16,542,282.
Oct‐
$16,542,282.
$39,050,895.
$30,000,100.
$25,593,077.
Nov‐
$25,593,077.
$61,431,540.
$30,000,000.
$57,024,618.
Dec‐
$57,024,618.
$157,424,176.
$119,600,200.
$94,848,595.
Jan‐
$94,848,595.
$229,631,928.
$170,000,000.
$154,480,523.
Feb‐
$154,480,523.
$215,548,479.
$120,000,000.
$250,029,003.
Mar‐
$250,029,003.
$290,254,504.
$440,000,000.
$100,283,508.
Apr‐
$100,283,508.
$715,253,589.
$700,000,000.
$115,537,098.
May‐
$115,537,098.
$984,363,749.
$608,040,407.
$491,860,440.

Page 21 Month
Op Bal U$
Credits #
Credits US$
Debits #
Debits US$
Cl Bal US$
Jun‐
$491,860,440.
$1,276,087,954.
$1,300,000,000.
$467,948,394.
Jul‐
$467,948,394.
$1,026,776,629.
$1,314,857,039.
$179,867,984.
Aug‐
$179,867,984.
$595,678,358.
$770,736,128.
$4,810,214.
Sep‐
$4,810,214.
$1,547,000,000.
$1,546,000,000.
$5,810,214.
Oct‐
$5,810,214.
$460,000,000.
$455,000,000.
$10,810,214.
Nov‐
$10,810,214.
$290,000,000.
$294,000,100.
$6,810,114.
Dec‐
$6,810,114.
$285,000,000.
$290,000,000.
$1,810,114.
Jan‐
$1,810,114.
$235,000,000.
$234,000,000.
$2,810,114.
Feb‐
$2,810,114.
$230,000,000.
$228,000,000.
$4,810,114.
Mar‐
$4,810,114.
$325,000,000.
$328,050,000.
$1,760,114.
Apr‐
$1,760,114.
$374,000,000.
$374,200,000.
$1,560,114.
May‐
$1,560,114.
$1,105,359,334.
Jun‐
$830,869,448.
Jul‐
$636,659,448.
Aug‐
$418,961,678.
Sep‐
$153,406,688.
$276,050,000.
$830,869,448.
$194,210,000.
$636,659,448.
$2,230.
$217,700,000.
$418,961,678.
$760.
$265,555,750.
$153,406,688.
$446,330,382.
$345,200,000.
$254,537,070.
THE WIND DOWN AND TRANSFER OF FUNDS
18.
On January 1, 2023, eight Binance/Zhao-owned companies had $58.
million on deposit. During that same time frame, $840 million was deposited into,
and $899 million was withdrawn, from those accounts. At the end of March, those
accounts had a zero balance except for one account with $180,000. Between January
and March 2023, multiple Binance accounts paid Binary Technology Development
Private Limited more than $162 million in offshore wires, as summarized here:
Beneficiary FI - Flowbank SA
London FFIC Binary
Technology Development PTE
LTD
Paying Entity
US$
BINANCE CAPITAL MANAGEMENT CO
$46,975,
BINANCE HOLDINGS LIMITED
$45,000,
BINANCE HOLDINGS LIMITED
$37,945,
BINANCE (AP) HOLDINGS LIMITED
$29,613,

Page 22 Beneficiary FI - Flowbank SA
London FFIC Binary
Technology Development PTE
LTD
Paying Entity
US$
BINANCE HOLDINGS (IE) LIMITED
$1,686,
BINANCE (SERVICES) HOLDINGS
$1,122,
BINANCE INVESTMENTS CO. LTD
$2,$162,346,
19.
As of May 27, 2023 all of these accounts have been closed or have a $
balance.
I declare under penalty of perjury under the laws of the United States of
America that the foregoing is true and correct.
Executed on June 5, 2023 in Washington, D.C.
______________________________
Sachin Verma

Page 23 Attachment Bank Account Activity in select Binance related accounts at Silvergate Bank and Signature Bank
Bank
Entity
Silvergate Bank BINANCE HOLDINGS LIMITED
Silvergate Bank BINANCE HOLDINGS LIMITED
Account
Deposits # Deposits US$
Withdrawals # Withdrawals US$ First Transaction Date Last Transaction Date
xxxxxx$6,270,981,4,$6,270,976,6/13/2/22/$146,203,$146,203,6/21/8/24/xxxxxx$6,417,185,$6,417,180,
Signature Bank BINANCE HOLDINGS LIMITED
Signature Bank BINANCE HOLDINGS LIMITED
xxxxxxxxxxxx
TOTAL ‐ BINANCE HOLDINGS LIMITED
$11,795,340,$464,452,$12,259,793,
$18,676,978,
$11,513,836,$463,936,$11,977,773,
4/27/12/17/
10/28/10/27/
$18,394,954,
Silvergate Bank BINANCE CAPITAL MANAGEMENT CO LTD
xxxxxx
$484,131,
2,
$483,131,
2/24/
2/22/
Signature Bank Binance Capital Management Co. LTD
Signature Bank Binance Capital Management Co. LTD
xxxxxxxxxxxx
$17,196,$904,981,$922,178,
$17,196,$904,981,$922,178,
8/13/12/29/
1/25/3/20/
TOTAL ‐ BINANCE CAPITAL MANAGEMENT CO. LTD
$1,406,309,
$1,405,309,
Silvergate Bank
Silvergate Bank
Silvergate Bank
Silvergate Bank
BAM MANAGEMENT US HOLDINGS INC
BAM MANAGEMENT US HOLDINGS INC
BAM MANAGEMENT US HOLDINGS INC
BAM MANAGEMENT US HOLDINGS INC
xxxxxxxxxxxxxxxxxxxxxxxx
$276,818,$260,852,$9,500,$$547,171,
2,
$276,818,$260,852,$9,500,$$547,171,
3/22/4/30/1/22/8/17/
2/3/2/22/7/20/2/22/
Signature Bank
Signature Bank
Signature Bank
Signature Bank
BAM MANAGEMENT US HOLDINGS INC
BAM MANAGEMENT US HOLDINGS INC
BAM MANAGEMENT US HOLDINGS INC
BAM MANAGEMENT US HOLDINGS INC
xxxxxxxxxxxxxxxxxxxxxxxx
$336,763,$13,436,$$$350,200,
$336,094,$12,704,$$$348,799,
5/24/1/24/2/3/2/22/
4/4/4/5/3/30/3/30/
7/2/8/26/8/26/12/30/1/21/9/22/12/30/
2/21/2/22/3/6/2/22/2/9/3/6/2/3/
TOTAL ‐ BAM MANAGEMENT US HOLDINGS INC.
Silvergate Bank
Silvergate Bank
Silvergate Bank
Silvergate Bank
Silvergate Bank
Silvergate Bank
Silvergate Bank
BAM TRADING SERVICES INC. SEN ACCOUNT
BAM TRADING SERVICES INC.
BAM TRADING SERVICES INC.
BAM TRADING SERVICES INC.
BAM TRADING SERVICES INC.
BAM TRADING SERVICES INC.
BAM TRADING SERVICES INC.
$897,372,xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
22,17,
$10,069,945,$625,601,$479,138,$463,137,$33,718,$6,750,$1,000,
$895,971,22,12,14,5,‐
$10,069,945,$625,601,$479,138,$463,137,$33,718,$83,$0

Page 24 Silvergate Bank BAM TRADING SERVICES INC.
xxxxxx
$$11,679,290,
$$11,671,623,
9/29/
2/3/
Signature Bank
Signature Bank
Signature Bank
Signature Bank
Signature Bank
Signature Bank
Signature Bank
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
$230,931,$191,814,$45,404,$30,888,$15,139,$6,005,$1,238,$521,421,
$229,250,$187,670,$39,100,$27,789,$15,139,$5,$238,$499,193,
11/25/10/21/7/27/5/31/5/31/11/1/12/12/
4/5/4/5/4/4/4/4/4/4/4/4/4/4/
BAM TRADING SERVICES INC.
BAM TRADING SERVICES INC.
BAM TRADING SERVICES INC.
BAM TRADING SERVICES INC.
BAM TRADING SERVICES INC.
BAM TRADING SERVICES INC.
BAM TRADING SERVICES INC. (Collateral Account)
TOTAL ‐ BAM TRADING SERVICES INC.
$12,200,712,
$12,170,816,
Silvergate Bank Merit Peak Limited
Silvergate Bank Merit Peak Limited
xxxxxxxxxxxx
1,
$21,947,605,$287,729,$22,235,334,
$21,947,605,$287,729,$22,235,334,
4/18/5/20/
12/8/12/7/
Signature Bank MERIT PEAK LIMITED
xxxxxx
$
$
5/6/
2/17/
TOTAL ‐ MERIT PEAK LIMITED
$22,235,334,
$22,235,334,
Silvergate Bank KEY VISION DEVELOPMENT LIMITED
Silvergate Bank KEY VISION DEVELOPMENT LIMITED
xxxxxxxxxxxx
7,197,
$11,288,369,$2,086,776,$13,375,145,
43,
$11,288,369,$2,086,776,$13,375,145,
9/30/10/16/
6/18/7/23/
Signature Bank KEY VISION DEVELOPMENT LIMITED
Signature Bank KEY VISION DEVELOPMENT LIMITED
Signature Bank KEY VISION DEVELOPMENT LIMITED
xxxxxxxxxxxxxxxxxx
512,
$5,366,444,$$250,017,$5,616,462,
134,‐
$5,366,444,$$250,000,$5,616,444,
8/10/8/19/1/4/
2/13/8/19/4/13/
TOTAL ‐ KEY VISION DEVELOPMENT LIMITED
$18,991,608,
$18,991,590,
Silvergate Bank SIGMA CHAIN AG
xxxxxx
493,632,
493,627,
6/13/
2/22/
Silvergate Bank BINANCE (SWITZERLAND) AG
xxxxxx
$308,644,
$308,644,
6/13/
2/22/
* Deposits and withdrawals totals include data up to March 31, 2023

Page 25 Attachment Select Information from Silvergate Bank Account Opening and Corporate Documents
Entity
Binance Holdings
Limited
Binance Capital
Management
Company Limited
BAM Management US
Holdings, Inc.
Corporate
Domicile
Delaware
British Virgin
Islands
Accounts
xxxxxxxxxxxx6717 (SEN)
xxxxxx
Beneficial Owner
Changpeng Zhao
Changpeng Zhao
Bank Accounts
Principal Officers* Signatory*
Guangying Chen
Changpeng Zhao
Guangying Chen
Changpeng Zhao
Changpeng Zhao
Guangying Chen
Delaware
xxxxxxxxxxxxxxxxxx9810 (SEN)
xxxxxx
BAM Management Wei Zhou
Company Limited
BAM Trading Services, Delaware
Inc.
xxxxxx3432 (SEN)
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
BAM Management Guangying Chen
US Holdings, Inc.
Binance Switzerland
AG
Merit Peak Limited
xxxxxxxxxxxx6675 (SEN)
xxxxxx5271 (SEN)
xxxxxx
Changpeng Zhao
Guangying Chen
Changpeng Zhao
Leslie Tam
Vincent Kwok
Guangying Chen
Guangying Chen
Guangying Chen
Changpeng Zhao
Guangying Chen
Changpeng Zhao
Guangying Chen
Sigma Chain
Switzerland
British Virgin
Islands
Switzerland
Key Vision
Seychelles
Development Limited
xxxxxxxxxxxx6691 (SEN)
xxxxxx5981 (SEN)
xxxxxx
Changpeng Zhao
Changpeng Zhao
* At least for one of several acocunts and for some points during the relevant period
Wei Zhou
Catherine Coley
Joshua Sroge
William Plon
Brian Shroder
Jasmine Yoonjung
Lee
Guangying Chen
Jasmine Yoonjung
Lee
Brian Walker
Shroder
Catherine Coley
Elaine Stone
Joshua Sroge
William Plon
Changpeng Zhao
Guangying Chen
Changpeng Zhao
Guangying Chen

Page 26 Attachment Select Information from Signature Bank Account Opening and Corporate Documents
Entity
Binance Holdings
Limited
Corporate
Domicile
Accounts
Cayman Islands xxxxxxxxxxxxxxxxxxBritish Virgin
xxxxxxIslands
xxxxxx
Binance Capital
Management
Company Limited
BAM Management US Delaware
Holdings, Inc.
BAM Trading Services, Delaware
Inc.
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
Beneficial Owner
Changpeng Zhao
Principal Officers* Bank Accounts Signatory*
Guangying Chen
Guangying Chen
Kaiser Ying Kit NG
Changpeng Zhao
Guangying Chen
Guangying Chen
Kaiser Ying Kit NG
Changpeng Zhao
William Plon
Jasmine Lee
Brian Shroder
Changpeng Zhao
Guangying Chen
Catherine Coley
William Plon
Jasmine Lee
Bifinity UAB (fka
Binance UAB)
Lithuania
xxxxxxxxxxxxxxxxxxxxxxxx
Changpeng Zhao
Changpeng Zhao
Guangying Chen
Kaiser Ying Kit NG
Saulius Galatiltis
Merit Peak Limited
British Virgin
Islands
Seychelles
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
Changpeng Zhao
Guangying Chen
Changpeng Zhao
Guangying Chen
Changpeng Zhao
(80%)
Guangying Chen
Kaiser Ying Kit Ng
Joselito Lizarondo
Changpeng Zhao
Kaiser Ying Kit Ng
xxxxxx
Guangying Chen
Seychelles
xxxxxx
Changpeng Zhao
Guangying Chen
Adrian Rhui Keong
Darren Makarem
Guangying Chen
Virgin Islands
(UK)
xxxxxxxxxxxx
Changpeng Zhao
Guangying Chen
Kaiser Ying Kit NG
xxxxxx
Changpeng Zhao
Kaiser Ying Kit Ng
xxxxxx
Changpeng Zhao
Guangying Chen
Kaiser Ying Kit NG
xxxxxx
Changpeng Zhao
Kaiser Ying Kit Ng
xxxxxx
Changpeng Zhao
Kaiser Ying Kit Ng
Key Vision
Development Limited
SWIPEWALLET EU OU Estonia
Cyber Shaft Enterprise
Limited
Binary Technology
Development PTE
Limited
Binance Investment
Company Limited
Prime Link
Management Limited
Virgin Islands
(UK)
Singapore
Binance Holdings (IE) Ireland
Limited
Binance Technologies Ireland
Limited
Binance (Services)
Ireland
Holdings Limited
Binance (AP) Holdings Ireland
Limited

Page 27 Binance Asia Services Singapore
Pte Ltd
xxxxxx
Changpeng Zhao
Guangying Chen
Adrian Rhui Keong
Darren Makarem
Binance Canada Asset Canada
Management Inc
xxxxxxxxxxxx
Changpeng Zhao
Binance Canada
Capital Markets Inc
Canada
Changpeng Zhao
Binance Canada
Holdings Limited
Canada
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
Binance Canada
Limited
Canada
xxxxxxxxxxxx
Changpeng Zhao
Binance (AD) Limited UAE
xxxxxx
Changpeng Zhao
Binance FZE
xxxxxx
Changpeng Zhao
xxxxxx
Changpeng Zhao
xxxxxx
Changpeng Zhao
Guangying Chen
Lawrence Trong Loung Truong
Susan Scullion
Guangying Chen
Lawrence Trong Loung Truong
Susan Scullion
Guangying Chen
Lawrence Trong Loung Truong
Susan Scullion
Guangying Chen
Lawrence Trong Loung Truong
Susan Scullion
Guangying Chen
Dominic Longman
Guangying Chen
Alexander Chehade
Guangying Chen
Vishal Sacheendran
Guangying Chen
Chaintecs Consulting Singapore
Singapore Private
Limited
xxxxxx
Changpeng Zhao
Guangying Chen
Kaiser Ying Kit Ng
Adrian Rhui Keong
Darren Makarem
Infozone Technologies Singapore
Private Limited
xxxxxx
Changpeng Zhao
Guangying Chen
Adrian Rhui Keong
Darren Makarem
Tornado Singapore
Technologies Private
Limited
Singapore
xxxxxx
Changpeng Zhao
(80%)
Guangying Chen
Adrian Rhui Keong
Darren Makarem
BN KZ Technologies
Limited
Kazakhstan
xxxxxx
Changpeng Zhao
Guangying Chen
Anton Keen
Cyper Technologies
SDN BHD
Malaysia
xxxxxx
Changpeng Zhao
Guangying Chen
Adrian Rhui Keong
Darren Makarem
UAE
BV Investment
UAE
Management Limited
BWIN Private Limited Singapore
Changpeng Zhao
* At least for one of several acocunts and for some points during the relevant period

PDF Page 1	PlainSite Cover Page

PDF Page 2	Case 1:23-cv-01599 Document 21 Filed 06/07/23 Page 1 of 27 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA __________________________________________ SECURITIES AND EXCHANGE ) COMMISSION, ) ) Plaintiff, ) ) v. ) ) BINANCE HOLDINGS LIMITED, ) BAM TRADING SERVICES INC., ) BAM MANAGEMENT US HOLDINGS ) INC., AND CHANGPENG ZHAO, ) ) Defendants. ) __________________________________________) Civil Action No. _______ DECLARATION OF SACHIN VERMA I, Sachin Verma, declare the following pursuant to Title 28, United States Code, Section 1746: 1. I am an active Certified Public Accountant with over 20 years of experience. I am currently employed by the United States Securities and Exchange Commission (“SEC”) in Washington, DC, as an Assistant Chief Accountant in the Division of Enforcement. As part of my daily activities, I have performed numerous reviews of financial records in connection with SEC investigations. 2. I submit this declaration in support of the SEC’s Motion for a Temporary Restraining Order and Preliminary Injunctions. The information set forth herein is based upon my personal review of financial records such as bank statements, deposits, cancelled checks, wire transfers, signature cards, and other account documents produced to the SEC by the defendants, Silvergate Bank, 1

PDF Page 3	Case 1:23-cv-01599 Document 21 Filed 06/07/23 Page 2 of 27 Signature Bank, FedWire and other parties pursuant to subpoenas and document requests (“financial records”) as of this date. My classification and summarization of financial records in this Declaration may change based on additional information that may be produced at a later date.1 I have cited to bates stamped document where applicable (“record documents”). 3. During the period from April 18, 2019 to April 5, 2023 (the “Relevant Period”), the corporate Defendants and many other corporate entities owned by Defendant Zhao held numerous accounts with two banks in the United States-Silvergate Bank and Signature Bank. 4. According to their websites, both banks had proprietary networks designed to enable their digital currency and institutional investor customers to send U.S. dollars and euros 24 hours a day between their accounts and the accounts of other bank customers. Silvergate promoted its SEN network as “Real-time USD and EUR settlement between counterparties, used by some of the largest exchanges in the world,” and “enabling near real-time transfers and immediate availability of funds.” Signature promoted its Signet Platform as leveraging blockchain technology to allow its commercial clients to make payments in U.S. dollars 24 hours a day, and “transactions made on the Signet Platform settle in real time, are safe and secure and incur no transaction fees.”2 2 Given the volume of the documents, they are not being attached, but can made available upon the Court’s request to the SEC’s counsel of record. 2 Wayback Machine for January 2023: Signet \| Signature Bank (archive.org); Wayback Machine December 2022: Silvergate Exchange Network Solutions \| Silvergate Bank \| San Diego (archive.org). 1

PDF Page 4	Case 1:23-cv-01599 Document 21 Filed 06/07/23 Page 3 of 27 5. I have reviewed account statements produced by Silvergate Bank for the following company accounts: Binance Holdings Limited, Binance Capital Management Co Ltd., BAM Management US Holdings Inc., BAM Trading Services Inc., Binance (Switzerland) AG, Sigma Chain AG, Merit Peak Limited, and Key Vision Development Limited. Many of those accounts participated in the SEN network. 6. I have reviewed account statements produced by Signature Bank for the following company accounts: Binance Holdings Limited, Binance Capital Management Inc., BAM Management US Holdings Inc., BAM Trading Services Inc., and Merit Peak Limited. Dozens of other Binance and non-Binance entities, all beneficially owned by Zhao, also held accounts at Signature Bank. Many of these bank accounts participated in the Signet network. 7. Attachment 1 summarizes the monthly activity in the Silvergate and Signature bank accounts of the above-mentioned companies and provides an overview of significant amounts of money moving through these accounts during 2019-2023, including through SEN and Signet accounts described above. Attachments 2 and 3 summarize the corporate domicile, the beneficial owner, officers and signatories during the relevant period. SILVERGATE ACCOUNTS 8. The following is a summary of account activity in the above-mentioned accounts at Silvergate Bank during the relevant period: 3

PDF Page 5	Case 1:23-cv-01599 Document 21 Filed 06/07/23 Page 4 of 27 KEY VISION DEVELOPMENT LIMITED a. Key Vision Development Limited is a Seychelles company beneficially owned by Zhao. The website address was identified as “Binance.com,” the email address was identified as fiat.finance@binance.com, and the number of employees was disclosed as “1000 (Binance).” The nature of its business was described as a cryptocurrency exchange to allow users to exchange digital assets. The expected funds flow activity was described as “Deposits: Fiat is wired to bank account, transfer fee paid at this point, Fiat will automatically convert to stablecoin (BUSD) when deposited. Withdrawals: BUSD converted to USD and withdrawn to client’s account.” b. In 2020 and 2021, Key Vision deposits and withdrawals both exceeded $13 billion (or $11 billion if internal transfers between Key Vision accounts at Silvergate Bank are excluded). Nearly all of the funds deposited into Key Vision accounts were transferred to an account in the name of Merit Peak Limited. Silvergate closed Key Vision’s accounts in mid-2021. MERIT PEAK LIMITED c. Relevant Merit Peak Limited financial records show that Merit Peak Limited is a British Virgin Islands company beneficially owned by Zhao.3 Its email address was identified as Solutions@Binance.com, and the nature of its business was described as OTC desk and proprietary trading of digital assets. Silvergate closed Merit Peak’s accounts in mid-2022. 3 BHL-SEC-BUSD-0021710. 4

PDF Page 6	Case 1:23-cv-01599 Document 21 Filed 06/07/23 Page 5 of 27 d. Between 2019 and 2021, Merit Peak accounts received $22 billion, including approximately $11 billion from Key Vision, $7.2 billion from other Binance entities, and $1.2 billion from BAM Trading. Merit Peak paid most of that money - $21.6 billion - to a foreign affiliate of Paxos TrustCompany, LLC (“Paxos”) the issuer of BUSD, a so-called stablecoin. This is summarized here: 2019-2021 Deposits Merit Peak Limited 2019-2021 Withdrawals Silvergate Bank Account Key Vision Development Limited $11,076,701,000 Binance Entities $7,187,710,000 BAM Trading Services Inc. $1,207,794,133 Paxos Global PTE LTD $21,557,032,027 Other $2,475,399,939 $390,573,045 Total $ 21,947,605,072 $21,947,605,072 $287,729,139 $287,729,139 $22,235,334,211 $22,235,334,211 Silvergate Bank Account Total SIGMA CHAIN e. Sigma Chain AG is a Swiss company beneficially owned by Zhao.4 Sigma Chain’s described business was as a market maker providing liquidity to fiat exchanges. Sigma Chain’s account was closed in February 2023. f. Between 2019 and 2023, Sigma Chain’s account received $494 million, including $184 million from Binance Holdings Limited, $145 million 4 SEC-SGB-E-0022457. 5

PDF Page 7	Case 1:23-cv-01599 Document 21 Filed 06/07/23 Page 6 of 27 from BAM Trading, $36 million from Binance Capital Management, and $15 million from Key Vision. During that period, Sigma Chain paid $494 million, including $160 million to BAM Trading Services, $131 million to Binance Holdings Limited, $21 million to Merit Peak , $2 million to Binance (Switzerland) AG, $32 million to Guangying Chen, and $10 million to Simpson Marine. This is summarized here: 2019-2023 Select Deposits 2019-2023 Select Withdrawals Binance Holdings Limited $184,250,000 $131,188,691 BAM Trading Services Inc. $145,000,100 $160,000,600 Sigma Chain Limited Silvergate Bank Account Binance Capital Management Co Ltd $36,000,000 Key Vision Development Limited $15,000,000 Merit Peak $21,000,100 Guangying Chen $32,430,435 Simpson Marine (S.E.A.) Pte Ltd $10,973,407 Binance (Switzerland) AG $2,253,649 Binance Capital Management Co Ltd $1,000,000 Other $113,382,576 $134,780,183 Total $493,632,676 $493,627,065 BAM MANAGEMENT US HOLDINGS INC. g. BAM Management US Holdings Inc., is a Delaware Company owned by BAM Management Company Limited, all of which is beneficially 6

PDF Page 8	Case 1:23-cv-01599 Document 21 Filed 06/07/23 Page 7 of 27 owned by Zhao.5 The last transaction date is February 22, 2023. Between 2019 and 2023 deposits and withdrawals exceeded $500 million. BAM TRADING SERVICES, INC. h. BAM Trading Services Inc., is a Delaware company owned by BAM Management US Holdings, Inc.6 Between 2019 and 2023, deposits and withdrawals for these accounts exceeded $11 billion. It received $4 billion from Prime Trust, $2.4 billion from Wintermute, $760 million from Subspace Capital LLC, $424 million from Coinbase, $380 million from KBIT Global, $349 million from Auros Tech Limited, $326 million from Tagomi Trading LLC, $318 million from Alameda Research Ltd Debtor in Possession, $160 million from Sigma Chain, $27 million from BAM Management Holdings, and $5 million from Merit Peak Limited. It sent $3.3 billion to Wintermute Trading, Limited, $1.5 billion to Alameda Research Ltd Debtor in Possession, $1.2 billion to Merit Peak Limited, $924 million to Auros Tech Limited, $683 million to Subspace Capital LLC, $665 million to KBIT Global Limited, $145 million to Sigma Chain. BINANCE (SWITZERLAND) AG i. Binance (Switzerland) AG is a Swiss company beneficially owned by Zhao.7 This account was closed in February 2023. Between 2019 and 2023, deposits and withdrawals for this account exceeded $300 million, most of which was received from Binance Holdings Limited, and paid out to a variety of BHL-SEC-BUSD-0220886. 6 BTS00462320. 7 SEC-SGB-E-0022453. 5 7

PDF Page 9	Case 1:23-cv-01599 Document 21 Filed 06/07/23 Page 8 of 27 companies, including other Binance entities, and $20.6 million in 2022 to a company beneficially owned by Guangying Chen, and $27.8 million to a company beneficially owned by Zhao. This is summarized here: 2019-2023 Select Deposits Binance Switzerland AG 2019-2023 Select Withdrawals Silvergate Bank Account $290,950,000 Binance Holdings Limited Chaintecs Consulting Singapore Pte. $27,761,443 Binance Europe Ltd. $23,781,131 Binary Technology Development Pte. $20,612,531 BINANCE HOLDINGS LIMITED j. Binance Holdings Limited is a Cayman Islands company beneficially owned by Zhao.8 Between 2019 and 2023, deposits and withdrawals for these accounts exceeded $6 billion. These accounts received approximately $5.6 billion from Binance Holdings Limited Signature Bank account, $131 million from Sigma Chain, $95 million from Merit Peak Limited, $5 million from Key Vision, and $17 million from Binance Capital Management Co. Limited, and paid approximately $4.2 billion to Merit Peak, $442 million to Binance Capital Management Company Limited, $270 million to Binance (Switzerland) AG, $184 million to Sigma Chain, and $29 million to Key Vision. This is summarized here: 8 SEC-SGB-E-0022398. 8

PDF Page 10	Case 1:23-cv-01599 Document 21 Filed 06/07/23 Page 9 of 27 2019-2023 Select Deposits Binance Holdings Limited 2019-2023 Select Withdrawals Silvergate Bank Accounts Binance Holdings Limited – Signature Bank $5,672,812,271 $131,188,691 $184,250,000 Merit Peak $95,063,978 $4,205,230,000 Binance Capital Management Co Ltd $17,000,500 $441,811,220 Sigma Chain $270,000,000 Binance (Switzerland) AG $5,000,000 Key Vision $29,040,486 BINANCE CAPITAL MANAGEMENT COMPANY LIMITED k. Binance Capital Management Company Limited is a British Virgin Islands company beneficially owned by Zhao.9 Between 2020 and 2023, deposits and withdrawals for these accounts exceeded $480 million, primarily through deposits from Binance Holdings Limited, and it paid approximately $36 million to Sigma Chain, and $17 million to Binance Holdings. SILVERGATE ACCOUNT CLOSURES l. On December 23, 2022, Silvergate informed Binance that it would be closing accounts for Binance (Switzerland) AG, Sigma Chain, Binance Capital Management Company, and Binance Holdings Limited, and directed the transfer of funds to be completed by February 22, 2023, at which point the 9 SEC-SGB-E-0022071. 9

PDF Page 11	Case 1:23-cv-01599 Document 21 Filed 06/07/23 Page 10 of 27 accounts would be closed. As of March 31, 2023, all of the accounts had zero balances. SIGNATURE ACCOUNTS 10. Many of the foregoing companies also held accounts at Signature Bank. Account information from Signature Bank includes the following: BAM MANAGEMENT US HOLDINGS INC. a. BAM Management US Holdings Inc., is a Delaware Company beneficially owned by Zhao. Between 2022 and 2023, deposits and withdrawals exceeded $350 million. BAM TRADING SERVICES b. BAM Trading Services is a Delaware Company beneficially owned by Zhao. Between 2019 and2023, deposits and withdrawals exceeded $500 million. MERIT PEAK LIMITED c. Merit Peak bank accounts show no activity during the relevant period. KEY VISION DEVELOPMENT LIMITEDi d. Key Vision is a Seychelles company beneficially owned by Zhao. Between 2020 and 2023, deposits and withdrawals exceeded $5.6 billion. BINANCE CAPITAL MANAGEMENT COMPANY LIMITED e. Binance Capital Management is a British Virgin Islands company beneficially owned by Zhao. Between 2021 and 2023, deposits and withdrawals exceed $900 million. Further information is summarized as follows: 10

PDF Page 12	Case 1:23-cv-01599 Document 21 Filed 06/07/23 Page 11 of 27 Binance Capital Management Company Limited 2021-2023 Select Deposits 2021-2023 Select Withdrawals $783,000,000 $50,069,978 $45,564,454 $9,000,000 Signature Bank Accounts Binance Holdings Limited Swipewallet EU OU $4,695,079 Cyber Shaft Enterprises Limited Zhao Changpeng $62,500,000 INSURED AIRCRAFT TITLE SERVICE, LLC $54,705,000 Flowbank SA FFC Binary Technology Development PTE Ltd $46,975,166 BINANCE HOLDINGS LIMITED f. Binance Holdings Limited is a Cayman company beneficially owned by Zhao. Between 2020 and 2022, deposits and withdrawals were approximately $12 billion. Further information is summarized as follows: 2020-2022 Select Deposits Binance Holdings Limited 2020-2022 Select Withdrawals Signature Bank Accounts Bifinity UAB $6,546,897,038 Worldpay B.V. $1,859,393,758 Wallet ID: xxxx $2,807,113,068 Binance Holdings Limited $5,557,501,000 Merit Peak $2,586,980,000 SWIPEWALLET EU OU $1,237,000,000 11

PDF Page 13	Case 1:23-cv-01599 Document 21 Filed 06/07/23 Page 12 of 27 Binance Capital Management Co. Ltd. $714,000,000 Binance Investments Company Limited $199,000,000 Prime Link Management Limited $105,000,000 Binance Holdings (IE) Limited $57,000,000 Binance Technologies Limited $27,000,000 Binance (Services) Holdings Limited $27,000,000 Binance Technologies Limited $20,000,000 OTHER SIGNATURE BANK ACCOUNTS HELD BY ZHAO-OWNED ENTITIES g. Zhao was also the beneficial owner of numerous other foreign companies with accounts at Signature Bank. These companies are foreign domiciled, including in Canada, UAE, Seychelles, Singapore, Lithuania, Kazakhstan, among others. These accounts were opened by a Binance.com employee, with Zhao as the listed beneficial owner, and Guangying Chen as the listed signatory. Some of these companies have “Binance” in their company name. Other companies do not bear the Binance name, but accounts were opened in the same fashion, listing Zhao as the beneficial owner and Guangying Chen as the signatory. Their links to Binance are consistent with a Binance organization chart10. 10 BHL-SEC-BUSD-0289617. 12

PDF Page 14	Case 1:23-cv-01599 Document 21 Filed 06/07/23 Page 13 of 27 SIGNIFICANT TRANSFERS 11. Binance Holdings Limited and Binance Capital Management show large deposits and withdrawals from and to Signature accounts for some Zhao-owned companies, and hundreds of millions of dollars have been transferred. BIFINITY UAB TRANSFERS BILLIONS OF DOLLARS TO BINANCE COMPANIES a. Bifinity UAB (fka Binance UAB) is a company located in Lithuania and beneficially owned by Zhao. The account opening documents state that Bifinity UAB is in the business of “provid[ing] revenue collection for Binance operators” conducting business in “Germany, UK, Netherlands and Switzerland.” The listed signatories on Bifinity accounts include Guangying Chen, and the account was opened by someone from Binance.com.11 b. Between 2020 and 2022, Bifinity UAB paid $6.5 billion to a Binance Holdings Limited account. In 2021, that Binance Holdings Limited account received $3 billion from Bifinity and $1.8 billion from WorldPay,12 making up the majority of deposits for the year. That money was transferred in 2021 out of Binance Holdings Limited to Merit Peak in direct wires for $2.5 billion and transferred $4.8 billion to another Binance Holdings account at Silvergate, which paid Merit Peak another $3.7 billion. 13 SIGB-H-0001-00000063. 12 WorldPay is a payments processing company that purports to provide Crypto trading platforms with the ability to move fiat money in and out of cryptocurrency. [https://www.protocol.com/fintech/worldpay-crypto-payments]. WorldPay paid Binance Holdings Limited $1.76 billion in 2021. 11

PDF Page 15	Case 1:23-cv-01599 Document 21 Filed 06/07/23 Page 14 of 27 2021 Significant movements of money between Zhao-owned entities Select Deposits Select Withdrawals Binance Holdings Limited Signature Bank Account From Bifinity UAB Signature Bank Account $3,012,000,000 From Worldpay B.V. $1,859,393,757 To Binance Holdings Limited Silvergate Bank Account $4,879,000,000 To Merit Peak Silvergate Account $2,586,980,000 Binance Holdings Limited Silvergate Bank From Binance Holdings Limited Signature Bank To Merit Peak Silvergate Bank Account c. $4,880,495,434 $3,735,000,000 In 2022, Bifinity transferred another $3.5 billion to the same Binance Holdings Limited account. $1.2 billion was transferred to an account held by Swipewallet EU OU, another Zhao-owned company. Bifinity sent another $304 million directly to Swipewallet. Swipewallet thereafter sent $1.5 billion in outgoing FX wires, in which USD is converted into a foreign currency before transmitting to the beneficiary. d. As for the rest of the money transferred by Bifinity, Binance Holdings Limited distributed approximately $911 million to other Binance Holdings accounts, $697 million to Binance Capital Management, and more than $415 million to other Zhao-owned companies. One of those Zhou-owned entities thereafter paid $62.5 million to a personal account held by Zhao, and 14

PDF Page 16	Case 1:23-cv-01599 Document 21 Filed 06/07/23 Page 15 of 27 in mid-March 2023 paid almost $47 million to a company beneficially owned by Guangying Chen. On March 14, 2023, that account wired $29,613,891.93 to an account held by Binance AP Holdings which was then wired out to the company owned by Guangying Chen that same day, transfers that are summarized here: 2022 Significant movements of money between Zhao-owned entities Select Deposits Select Withdrawals Binance Holdings Limited Signature Bank Account From Bifinity UAB Signature Bank Account To Swipewallet Eu Ou Signature Bank Account $3,534,897,037 $1,237,000,000 To Binance Holdings Limited Accounts ‐ Binance Holdings Limited Silvergate Bank Account $463,000,000 ‐ Binance Holdings Limited Signature Bank Account 448,000,000 ‐ Sub-total $911,000,000 To Binance Capital Management Co. Ltd. Signature Bank Account 697,000,000 To Zhao-owned companies ‐ Binance Investments Co. Ltd. Signature Bank Account 162,000,000 ‐ Prime Link Management Limited Signature Bank Account $85,000,000 ‐ Binance Holdings (IE) Limited Signature Bank Account $57,000,000 15

PDF Page 17	Case 1:23-cv-01599 Document 21 Filed 06/07/23 Page 16 of 27 2022 Significant movements of money between Zhao-owned entities Select Deposits Select Withdrawals ‐ Binance Technologies Limited Signature Bank Account $27,000,000 ‐ Binance (Services) Holdings Limited Signature Bank Account $27,000,000 ‐ Swipewallet EU OU Signature Bank Account $23,400,000 ‐ Binance Technologies Limited Signature Bank Account $20,000,000 ‐ Other $13,695,750 ‐ Sub-total $415,095,750 Swipewallet EU OU Signature Bank Account From Binance Holdings Limited Signature Bank $1,273,000,000 From Bifinity UAB Silvergate Bank Account $304,000,000 To Outgoing FX Wire $1,575,816,134 Binance Capital Management Co. Ltd. Signature Bank Account (includes select 2023 withdrawals totaling $79,089,058) From Binance Holdings Limited Signature Bank Account $697,000,000 To Zhao Changpeng Signature Bank Account ($60m in 2022 and $2.5m in 2023) $62,500,000 To Flowbank SA FFC Binary Technology Development PTE Ltd (a company beneficially owned by Guangying Chen) $46,975,166* 16

PDF Page 18	Case 1:23-cv-01599 Document 21 Filed 06/07/23 Page 17 of 27 2022 Significant movements of money between Zhao-owned entities Select Deposits To Binance (AP) Holding Limited Signature Bank Account; further transferred from Binance (AP) Holdings Limited on March 14, 2023 to Flowbank SA FFC FFC Binary Technology Development PTE Ltd (a company beneficially owned by Guangying Chen) Select Withdrawals $29,613,892* BINANCE COMMINGLED FUNDS AT MERIT PEAK FOR FURTHER TRANSFER TO PAXOS 12. Millions of dollars from Binance related accounts were commingled in Merit Peak’s accounts. For example, in 2021, funds from Key Vision ($11.05 billion), Prime Trust ($1.1 billion) (through BAM Trading) and Bifinity UAB ($6.3 billion) (through Binance Holdings Limited) were transferred to Merit Peak and Merit Peak transferred all of that money as part of its transfers of almost $20 billion to a foreign affiliate of Paxos in 2021, summarized as follows: 2021 Merit Peak Select Account Activity Select Deposits Select Withdrawals Merit Peak Silvergate Bank Account From Key Vision Development Limited $ 11,054,700,000 From Binance Holdings Limited $ 6,321,980,000 From BAM Trading Services Inc. $1,154,753,502 To Paxos Global PTE Ltd $19,975,961,032 LARGE AMOUNTS OF MONEY MOVE ACROSS BINANCE AND ZHAO-OWNED BANK ACCOUNTS 13. The transactions in many of the Binance or Zhao-owned company accounts held at Silvergate Bank and Signature Bank show large amounts of money 17

PDF Page 19	Case 1:23-cv-01599 Document 21 Filed 06/07/23 Page 18 of 27 flowing in and out of the accounts. The large incoming credits are followed by outgoing debits within days, with the result that the accounts maintain a relatively much lower balance at month’s beginning and end. 14. For example, in one Silvergate Binance Holdings 2022 account statement, money is credited monthly from another Binance Holdings account, accounting for most of monthly credits, and most of those credits are debited to Binance Capital Management Limited and Binance Switzerland in interbank transfers. In February 2022, for example, the account has a beginning balance of $7.6M and an ending balance of $7.7M, but in that month $20 million was deposited from another Binance Holdings account, $11M was wired to Binance Switzerland AG, and $6M was wired to Binance Capital Management, as summarized here: Feb 2022 Binance Holdings Limited Silvergate Bank Account Deposits From Binance Holdings Limited Withdrawals $20,000,000 To Binance (Switzerland) AG $11,000,000 To Binance Capital Management Co Ltd $6,000,000 Other $94,478 $2,944,633 Total $20,094,478 $19,944,633 15. Month This pattern of money flow repeats over months, as summarized here: Op Bal U$ Credits # Credits US$ Debits # Debits US$ Cl Bal US$ Jun‐19 $0.00 2 $500,100.00 4 $10,100.00 $489,990.00 Jul‐19 $489,990.00 1 $1,000,000.00 18 $984,795.78 $505,194.22 Aug‐19 $505,194.22 0 $0.00 30 $285,127.80 $220,066.42 Sep‐19 $220,066.42 4 $1,234,385.00 78 $880,946.78 $573,504.64 Oct‐19 $573,504.64 8 $1,017,019.00 38 $1,221,165.05 $369,358.59 Nov‐19 $369,358.59 6 $2,029,321.10 126 $1,414,107.41 $984,572.28 Dec‐19 $984,572.28 14 $843,123.60 86 $1,118,487.47 $709,208.41 Jan‐20 $709,208.41 32 $4,125,860.47 110 $2,393,223.98 $2,441,844.90 Feb‐20 $2,441,844.90 24 $13,198,338.39 128 $3,269,227.65 $12,370,955.64 18

PDF Page 20	Case 1:23-cv-01599 Document 21 Filed 06/07/23 Page 19 of 27 Month Op Bal U$ Credits # Credits US$ Debits # Debits US$ Cl Bal US$ Mar‐20 $12,370,955.64 38 $38,782,117.78 116 $38,403,462.96 $12,749,610.46 Apr‐20 $12,749,610.46 32 $37,816,051.50 104 $33,842,419.03 $16,723,242.93 May‐20 $16,723,242.93 29 $15,676,090.45 106 $19,467,858.76 $12,931,474.62 Jun‐20 $12,931,474.62 90 $40,970,092.70 104 $20,622,814.43 $33,278,752.89 Jul‐20 $33,278,752.89 80 $49,078,856.96 122 $24,545,274.51 $57,812,335.34 Aug‐20 $57,812,335.34 68 $96,371,547.65 145 $93,282,559.04 $60,901,323.95 Sep‐20 $60,901,323.95 44 $123,915,287.67 116 $95,746,400.45 $89,070,211.17 Oct‐20 $89,070,211.17 31 $55,147,022.33 166 $20,301,712.96 $123,915,520.54 Nov‐20 $123,915,520.54 35 $62,021,156.50 146 $81,150,012.04 $104,786,665.00 Dec‐20 $104,786,665.00 20 $91,943,354.54 175 $129,090,458.91 $67,639,560.63 Jan‐21 $67,639,560.03 26 $183,316,090.57 143 $182,693,697.50 $68,261,953.70 Feb‐21 $68,261,953.70 22 $156,404,925.86 111 $174,525,739.29 $50,141,140.27 Mar‐21 $50,141,140.27 13 $445,542,017.62 157 $390,911,068.29 $104,772,089.60 Apr‐21 $104,772,089.60 13 $730,177,804.24 181 $727,463,722.90 $107,486,170.94 May‐21 $107,486,170.94 19 $607,146,622.44 155 $699,651,009.08 $14,981,784.30 Jun‐21 $14,981,784.30 22 $1,345,148,277.92 190 $1,356,483,954.81 $3,646,107.41 Jul‐21 $3,646,107.41 11 $689,091,808.59 175 $653,516,941.58 $39,220,974.42 Aug‐21 $39,220,974.42 10 $201,614,930.58 141 $194,182,505.70 $46,653,399.30 Sep‐21 $46,653,399.30 8 $131,746,373.38 138 $162,680,683.28 $15,719,089.40 Oct‐21 $15,719,089.40 14 $182,695,791.41 141 $176,397,036.13 $22,017,844.68 $14,189,579.02 Nov‐21 $22,017,844.68 12 $170,671,158.88 124 $178,499,424.54 Dec‐21 $14,189,579.02 20 $213,074,672.89 112 $220,832,010.62 $6,432,241.29 Jan‐22 $6,432,241.29 8 $125,131,745.39 95 $123,952,326.66 $7,611,660.02 Feb‐22 $7,611,660.02 5 $20,094,477.98 85 $19,944,633.00 $7,761,505.00 Mar‐22 $7,761,505.00 10 $63,055,614.46 118 $68,472,212.11 $2,344,907.35 Apr‐22 $2,344,907.35 8 $30,082,889.11 71 $26,153,168.03 $6,274,628.43 May‐22 $6,274,628.43 6 $20,029,852.77 96 $25,375,756.65 $928,724.55 Jun‐22 $928,724.55 7 $30,117,791.61 86 $25,600,996.25 $5,445,519.91 Jul‐22 $5,445,519.91 5 $75,001,495.75 70 $72,794,948.93 $7,652,066.73 Aug‐22 $7,652,066.73 4 $35,029,287.89 109 $33,437,711.77 $9,243,642.85 Sep‐22 $9,243,642.85 9 $30,207,449.20 114 $30,444,908.01 $9,006,184.04 Oct‐22 $9,006,184.04 4 $35,006,000.00 105 $31,721,664.67 $12,290,519.37 Nov‐22 $12,290,519.37 10 $23,711,567.49 66 $35,520,037.16 $482,049.70 Dec‐22 $482,049.70 13 $42,446,512.27 56 $42,533,743.53 $394,818.44 Jan‐23 $394,818.44 14 $26,595,081.18 50 $26,833,171.71 $156,727.91 Feb‐23 $156,727.91 15 $22,171,640.58 38 $22,323,256.39 $5,112.10 16. At times the amounts being credited and debited during a single month amounts to movement of more than a billion dollars. For example, in July 2021, one Signature Bank Binance Holdings account shows a starting balance of $468 million, deposits of $1 billion, withdrawals of $1.3 billion, and an ending balance of $179 million. Incoming wires come from WorldPay and are paid out to Merit Peak, 19

PDF Page 21	Case 1:23-cv-01599 Document 21 Filed 06/07/23 Page 20 of 27 another Binance Holdings account and other assorted payments in wires ranging from $10 million to $100 million increments. July 2021 Binance Holdings Limited Signature Bank Account Deposits From Wallet ID:xxxx $561,043,603 From Wallet ID: xxxx $265,807,069 From WORLDPAY B.V. $169,925,973 Withdrawals $29,999,985 From UAB FINANSINES PASLAUGOS CONTIS To Binance Holdings Limited Silvergate Bank Account $689,000,000 To Merit Peak Limited Silvergate Bank $569,980,000 To UAB FINANSINES PASLAUGOS CONTIS $30,000,000 To Amazon Web Services, Inc. ACCT $15,000,000 To Stifel Bank $10,877,039 $1,026,776,630 Total 17. $1,314,857,039 A monthly summary of this Binance Holdings Limited account shows the following: Month Op Bal U$ Credits # Credits US$ Debits # Debits US$ Cl Bal US$ Mar‐20 $0.00 0 $0.00 0 $0.00 $0.00 Apr‐20 $0.00 3 $2,010,000.00 0 $0.00 $2,010,000.00 May‐20 $2,010,000.00 0 $0.00 0 $0.00 $2,010,000.00 Jun‐20 $2,010,000.00 6 $30,441.41 4 $7,192.42 $2,033,248.99 Jul‐20 $2,033,248.99 17 $1,886,088.85 0 $0.00 $3,919,337.44 Aug‐20 $3,919,337.84 20 $12,844,171.94 0 $0.00 $16,763,509.78 Sep‐20 $16,763,509.78 42 $65,278,772.49 8 $65,500,000.00 $16,542,282.27 Oct‐20 $16,542,282.27 26 $39,050,895.54 4 $30,000,100.00 $25,593,077.81 Nov‐20 $25,593,077.81 24 $61,431,540.62 3 $30,000,000.00 $57,024,618.43 Dec‐20 $57,024,618.43 25 $157,424,176.73 13 $119,600,200.00 $94,848,595.16 Jan‐21 $94,848,595.16 23 $229,631,928.69 17 $170,000,000.00 $154,480,523.85 Feb‐21 $154,480,523.85 20 $215,548,479.94 8 $120,000,000.00 $250,029,003.79 Mar‐21 $250,029,003.79 25 $290,254,504.27 6 $440,000,000.00 $100,283,508.56 Apr‐21 $100,283,508.56 24 $715,253,589.87 7 $700,000,000.00 $115,537,098.43 May‐21 $115,537,098.43 20 $984,363,749.60 11 $608,040,407.68 $491,860,440.35 20

PDF Page 22	Case 1:23-cv-01599 Document 21 Filed 06/07/23 Page 21 of 27 Month Op Bal U$ Credits # Credits US$ Debits # Debits US$ Cl Bal US$ Jun‐21 $491,860,440.35 24 $1,276,087,954.04 15 $1,300,000,000.00 $467,948,394.39 Jul‐21 $467,948,394.39 32 $1,026,776,629.74 16 $1,314,857,039.46 $179,867,984.67 Aug‐21 $179,867,984.67 20 $595,678,358.63 14 $770,736,128.84 $4,810,214.46 Sep‐21 $4,810,214.46 18 $1,547,000,000.00 24 $1,546,000,000.00 $5,810,214.46 Oct‐21 $5,810,214.46 8 $460,000,000.00 16 $455,000,000.00 $10,810,214.46 Nov‐21 $10,810,214.46 9 $290,000,000.00 14 $294,000,100.00 $6,810,114.46 Dec‐21 $6,810,114.46 11 $285,000,000.00 12 $290,000,000.00 $1,810,114.46 Jan‐22 $1,810,114.46 9 $235,000,000.00 14 $234,000,000.00 $2,810,114.46 Feb‐22 $2,810,114.46 11 $230,000,000.00 17 $228,000,000.00 $4,810,114.46 Mar‐22 $4,810,114.46 12 $325,000,000.00 26 $328,050,000.00 $1,760,114.46 Apr‐22 $1,760,114.48 12 $374,000,000.00 16 $374,200,000.00 $1,560,114.46 May‐22 $1,560,114.46 16 $1,105,359,334.17 Jun‐22 $830,869,448.63 Jul‐22 $636,659,448.63 1 Aug‐22 $418,961,678.63 Sep‐22 $153,406,688.55 17 $276,050,000.00 $830,869,448.63 22 $194,210,000.00 $636,659,448.63 $2,230.00 15 $217,700,000.00 $418,961,678.63 1 $760.00 24 $265,555,750.08 $153,406,688.55 2 $446,330,382.26 27 $345,200,000.00 $254,537,070.81 THE WIND DOWN AND TRANSFER OF FUNDS 18. On January 1, 2023, eight Binance/Zhao-owned companies had $58.7 million on deposit. During that same time frame, $840 million was deposited into, and $899 million was withdrawn, from those accounts. At the end of March, those accounts had a zero balance except for one account with $180,000. Between January and March 2023, multiple Binance accounts paid Binary Technology Development Private Limited more than $162 million in offshore wires, as summarized here: Beneficiary FI - Flowbank SA London FFIC Binary Technology Development PTE LTD Paying Entity US$ BINANCE CAPITAL MANAGEMENT CO $46,975,166 BINANCE HOLDINGS LIMITED $45,000,000 BINANCE HOLDINGS LIMITED $37,945,943 BINANCE (AP) HOLDINGS LIMITED $29,613,892 21

PDF Page 23	Case 1:23-cv-01599 Document 21 Filed 06/07/23 Page 22 of 27 Beneficiary FI - Flowbank SA London FFIC Binary Technology Development PTE LTD Paying Entity US$ BINANCE HOLDINGS (IE) LIMITED $1,686,560 BINANCE (SERVICES) HOLDINGS $1,122,835 BINANCE INVESTMENTS CO. LTD $2,200 $162,346,596 19. As of May 27, 2023 all of these accounts have been closed or have a $0 balance. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on June 5, 2023 in Washington, D.C. ______________________________ Sachin Verma 22

PDF Page 24	Case 1:23-cv-01599 Document 21 Filed 06/07/23 Page 23 of 27 Attachment 1 Bank Account Activity in select Binance related accounts at Silvergate Bank and Signature Bank Bank Entity Silvergate Bank BINANCE HOLDINGS LIMITED Silvergate Bank BINANCE HOLDINGS LIMITED Account Deposits # Deposits US$ Withdrawals # Withdrawals US$ First Transaction Date Last Transaction Date xxxxxx6709 866 $6,270,981,606 4,845 $6,270,976,494 6/13/2019 2/22/2023 34 $146,203,978 26 $146,203,978 6/21/2019 8/24/2020 xxxxxx6717 $6,417,185,584 $6,417,180,472 Signature Bank BINANCE HOLDINGS LIMITED Signature Bank BINANCE HOLDINGS LIMITED xxxxxx5685 xxxxxx7894 464 31 TOTAL ‐ BINANCE HOLDINGS LIMITED $11,795,340,667 $464,452,500 $12,259,793,167 393 291 $18,676,978,750 $11,513,836,918 $463,936,859 $11,977,773,777 4/27/2020 12/17/2021 10/28/2022 10/27/2022 $18,394,954,249 Silvergate Bank BINANCE CAPITAL MANAGEMENT CO LTD xxxxxx1220 145 $484,131,038 2,080 $483,131,038 2/24/2020 2/22/2023 Signature Bank Binance Capital Management Co. LTD Signature Bank Binance Capital Management Co. LTD xxxxxx7217 xxxxxx7908 11 61 $17,196,736 $904,981,456 $922,178,192 150 308 $17,196,736 $904,981,456 $922,178,192 8/13/2021 12/29/2021 1/25/2023 3/20/2023 TOTAL ‐ BINANCE CAPITAL MANAGEMENT CO. LTD $1,406,309,230 $1,405,309,230 Silvergate Bank Silvergate Bank Silvergate Bank Silvergate Bank BAM MANAGEMENT US HOLDINGS INC BAM MANAGEMENT US HOLDINGS INC BAM MANAGEMENT US HOLDINGS INC BAM MANAGEMENT US HOLDINGS INC xxxxxx7846 xxxxxx4563 xxxxxx9810 xxxxxx7853 47 339 6 21 $276,818,473 $260,852,762 $9,500,000 $586 $547,171,821 30 2,801 6 83 $276,818,473 $260,852,762 $9,500,000 $586 $547,171,821 3/22/2022 4/30/2019 1/22/2020 8/17/2022 2/3/2023 2/22/2023 7/20/2020 2/22/2023 Signature Bank Signature Bank Signature Bank Signature Bank BAM MANAGEMENT US HOLDINGS INC BAM MANAGEMENT US HOLDINGS INC BAM MANAGEMENT US HOLDINGS INC BAM MANAGEMENT US HOLDINGS INC xxxxxx0684 xxxxxx8310 xxxxxx3338 xxxxxx3346 24 34 2 1 $336,763,392 $13,436,798 $453 $92 $350,200,735 24 316 1 1 $336,094,401 $12,704,912 $453 $92 $348,799,857 5/24/2022 1/24/2023 2/3/2023 2/22/2023 4/4/2023 4/5/2023 3/30/2023 3/30/2023 7/2/2020 8/26/2021 8/26/2021 12/30/2019 1/21/2022 9/22/2021 12/30/2019 2/21/2023 2/22/2023 3/6/2023 2/22/2023 2/9/2023 3/6/2023 2/3/2023 TOTAL ‐ BAM MANAGEMENT US HOLDINGS INC. Silvergate Bank Silvergate Bank Silvergate Bank Silvergate Bank Silvergate Bank Silvergate Bank Silvergate Bank BAM TRADING SERVICES INC. SEN ACCOUNT BAM TRADING SERVICES INC. BAM TRADING SERVICES INC. BAM TRADING SERVICES INC. BAM TRADING SERVICES INC. BAM TRADING SERVICES INC. BAM TRADING SERVICES INC. $897,372,556 xxxxxx3432 xxxxxx1295 xxxxxx6245 xxxxxx1113 xxxxxx7416 xxxxxx1377 xxxxxx1121 22,629 17,886 904 979 259 7 2 $10,069,945,157 $625,601,386 $479,138,011 $463,137,117 $33,718,466 $6,750,000 $1,000,100 $895,971,678 22,989 12,260 14,410 5,877 7 3 ‐ $10,069,945,157 $625,601,386 $479,138,011 $463,137,117 $33,718,466 $83,192 $0

PDF Page 25	Case 1:23-cv-01599 Document 21 Filed 06/07/23 Page 24 of 27 Silvergate Bank BAM TRADING SERVICES INC. xxxxxx3424 2 $526 $11,679,290,764 4 $526 $11,671,623,856 9/29/2020 2/3/2023 Signature Bank Signature Bank Signature Bank Signature Bank Signature Bank Signature Bank Signature Bank xxxxxx5315 xxxxxx2547 xxxxxx2555 xxxxxx5323 xxxxxx5331 xxxxxx7211 xxxxxx6907 28 135 208 185 7 4 2 $230,931,536 $191,814,339 $45,404,285 $30,888,393 $15,139,830 $6,005,270 $1,238,101 $521,421,755 382 243 4 238 5 2 1 $229,250,897 $187,670,282 $39,100,000 $27,789,032 $15,139,593 $5,270 $238,001 $499,193,075 11/25/2019 10/21/2022 7/27/2022 5/31/2022 5/31/2022 11/1/2022 12/12/2019 4/5/2023 4/5/2023 4/4/2023 4/4/2023 4/4/2023 4/4/2023 4/4/2023 BAM TRADING SERVICES INC. BAM TRADING SERVICES INC. BAM TRADING SERVICES INC. BAM TRADING SERVICES INC. BAM TRADING SERVICES INC. BAM TRADING SERVICES INC. BAM TRADING SERVICES INC. (Collateral Account) TOTAL ‐ BAM TRADING SERVICES INC. $12,200,712,519 $12,170,816,931 Silvergate Bank Merit Peak Limited Silvergate Bank Merit Peak Limited xxxxxx5271 xxxxxx5263 1,122 230 $21,947,605,072 $287,729,139 $22,235,334,211 882 190 $21,947,605,072 $287,729,139 $22,235,334,211 4/18/2019 5/20/2019 12/8/2021 12/7/2021 Signature Bank MERIT PEAK LIMITED xxxxxx3512 1 $100 1 $100 5/6/2021 2/17/2023 TOTAL ‐ MERIT PEAK LIMITED $22,235,334,311 $22,235,334,311 Silvergate Bank KEY VISION DEVELOPMENT LIMITED Silvergate Bank KEY VISION DEVELOPMENT LIMITED xxxxxx5981 xxxxxx6500 7,323 197,206 $11,288,369,703 $2,086,776,079 $13,375,145,782 408 43,183 $11,288,369,703 $2,086,776,079 $13,375,145,782 9/30/2020 10/16/2020 6/18/2021 7/23/2021 Signature Bank KEY VISION DEVELOPMENT LIMITED Signature Bank KEY VISION DEVELOPMENT LIMITED Signature Bank KEY VISION DEVELOPMENT LIMITED xxxxxx6221 xxxxxx9952 xxxxxx6795 512,239 1 9 $5,366,444,576 $500 $250,017,808 $5,616,462,884 134,836 ‐ 17 $5,366,444,576 $0 $250,000,000 $5,616,444,576 8/10/2021 8/19/2020 1/4/2022 2/13/2023 8/19/2020 4/13/2022 TOTAL ‐ KEY VISION DEVELOPMENT LIMITED $18,991,608,666 $18,991,590,358 Silvergate Bank SIGMA CHAIN AG xxxxxx6683 168 493,632,676 664 493,627,065 6/13/2019 2/22/2023 Silvergate Bank BINANCE (SWITZERLAND) AG xxxxxx6667 135 $308,644,449 702 $308,644,448 6/13/2019 2/22/2023 * Deposits and withdrawals totals include data up to March 31, 2023

PDF Page 26	Case 1:23-cv-01599 Document 21 Filed 06/07/23 Page 25 of 27 Attachment 2 Select Information from Silvergate Bank Account Opening and Corporate Documents Entity Binance Holdings Limited Binance Capital Management Company Limited BAM Management US Holdings, Inc. Corporate Domicile Delaware British Virgin Islands Accounts xxxxxx6709 xxxxxx6717 (SEN) xxxxxx1220 Beneficial Owner Changpeng Zhao Changpeng Zhao Bank Accounts Principal Officers* Signatory* Guangying Chen Changpeng Zhao Guangying Chen Changpeng Zhao Changpeng Zhao Guangying Chen Delaware xxxxxx7846 xxxxxx4563 xxxxxx9810 (SEN) xxxxxx7853 BAM Management Wei Zhou Company Limited BAM Trading Services, Delaware Inc. xxxxxx3432 (SEN) xxxxxx1295 xxxxxx6245 xxxxxx1113 xxxxxx7416 xxxxxx1377 xxxxxx1121 xxxxxx3424 BAM Management Guangying Chen US Holdings, Inc. Binance Switzerland AG Merit Peak Limited xxxxxx6667 xxxxxx6675 (SEN) xxxxxx5271 (SEN) xxxxxx5263 Changpeng Zhao Guangying Chen Changpeng Zhao Leslie Tam Vincent Kwok Guangying Chen Guangying Chen Guangying Chen Changpeng Zhao Guangying Chen Changpeng Zhao Guangying Chen Sigma Chain Switzerland British Virgin Islands Switzerland Key Vision Seychelles Development Limited xxxxxx6683 xxxxxx6691 (SEN) xxxxxx5981 (SEN) xxxxxx6500 Changpeng Zhao Changpeng Zhao * At least for one of several acocunts and for some points during the relevant period Wei Zhou Catherine Coley Joshua Sroge William Plon Brian Shroder Jasmine Yoonjung Lee Guangying Chen Jasmine Yoonjung Lee Brian Walker Shroder Catherine Coley Elaine Stone Joshua Sroge William Plon Changpeng Zhao Guangying Chen Changpeng Zhao Guangying Chen

PDF Page 27	Case 1:23-cv-01599 Document 21 Filed 06/07/23 Page 26 of 27 Attachment 3 Select Information from Signature Bank Account Opening and Corporate Documents Entity Binance Holdings Limited Corporate Domicile Accounts Cayman Islands xxxxxx5685 xxxxxx7894 xxxxxx5693 British Virgin xxxxxx7908 Islands xxxxxx7217 Binance Capital Management Company Limited BAM Management US Delaware Holdings, Inc. BAM Trading Services, Delaware Inc. xxxxxx0684 xxxxxx8310 xxxxxx3338 xxxxxx3346 xxxxxx5315 xxxxxx2547 xxxxxx2555 xxxxxx5323 xxxxxx5331 xxxxxx7211 xxxxxx6907 Beneficial Owner Changpeng Zhao Principal Officers* Bank Accounts Signatory* Guangying Chen Guangying Chen Kaiser Ying Kit NG Changpeng Zhao Guangying Chen Guangying Chen Kaiser Ying Kit NG Changpeng Zhao William Plon Jasmine Lee Brian Shroder Changpeng Zhao Guangying Chen Catherine Coley William Plon Jasmine Lee Bifinity UAB (fka Binance UAB) Lithuania xxxxxx9360 xxxxxx7924 xxxxxx8615 xxxxxx8381 Changpeng Zhao Changpeng Zhao Guangying Chen Kaiser Ying Kit NG Saulius Galatiltis Merit Peak Limited British Virgin Islands Seychelles xxxxxx3512 xxxxxx3520 xxxxxx6221 xxxxxx9952 xxxxxx6795 xxxxxx7878 xxxxxx7886 xxxxxx7319 xxxxxx7327 xxxxxx7993 Changpeng Zhao Guangying Chen Changpeng Zhao Guangying Chen Changpeng Zhao (80%) Guangying Chen Kaiser Ying Kit Ng Joselito Lizarondo Changpeng Zhao Kaiser Ying Kit Ng xxxxxx1441 Guangying Chen Seychelles xxxxxx2361 Changpeng Zhao Guangying Chen Adrian Rhui Keong Darren Makarem Guangying Chen Virgin Islands (UK) xxxxxx7225 xxxxxx7916 Changpeng Zhao Guangying Chen Kaiser Ying Kit NG xxxxxx7139 Changpeng Zhao Kaiser Ying Kit Ng xxxxxx2030 Changpeng Zhao Guangying Chen Kaiser Ying Kit NG xxxxxx4989 Changpeng Zhao Kaiser Ying Kit Ng xxxxxx8000 Changpeng Zhao Kaiser Ying Kit Ng Key Vision Development Limited SWIPEWALLET EU OU Estonia Cyber Shaft Enterprise Limited Binary Technology Development PTE Limited Binance Investment Company Limited Prime Link Management Limited Virgin Islands (UK) Singapore Binance Holdings (IE) Ireland Limited Binance Technologies Ireland Limited Binance (Services) Ireland Holdings Limited Binance (AP) Holdings Ireland Limited

PDF Page 28	Case 1:23-cv-01599 Document 21 Filed 06/07/23 Page 27 of 27 Binance Asia Services Singapore Pte Ltd xxxxxx6693 Changpeng Zhao Guangying Chen Adrian Rhui Keong Darren Makarem Binance Canada Asset Canada Management Inc xxxxxx9031 xxxxxx9325 Changpeng Zhao Binance Canada Capital Markets Inc Canada Changpeng Zhao Binance Canada Holdings Limited Canada xxxxxx9058 xxxxxx0912 xxxxxx9333 xxxxxx9066 xxxxxx9341 Binance Canada Limited Canada xxxxxx9368 xxxxxx9074 Changpeng Zhao Binance (AD) Limited UAE xxxxxx7814 Changpeng Zhao Binance FZE xxxxxx8934 Changpeng Zhao xxxxxx9795 Changpeng Zhao xxxxxx0808 Changpeng Zhao Guangying Chen Lawrence Trong Loung Truong Susan Scullion Guangying Chen Lawrence Trong Loung Truong Susan Scullion Guangying Chen Lawrence Trong Loung Truong Susan Scullion Guangying Chen Lawrence Trong Loung Truong Susan Scullion Guangying Chen Dominic Longman Guangying Chen Alexander Chehade Guangying Chen Vishal Sacheendran Guangying Chen Chaintecs Consulting Singapore Singapore Private Limited xxxxxx1433 Changpeng Zhao Guangying Chen Kaiser Ying Kit Ng Adrian Rhui Keong Darren Makarem Infozone Technologies Singapore Private Limited xxxxxx1277 Changpeng Zhao Guangying Chen Adrian Rhui Keong Darren Makarem Tornado Singapore Technologies Private Limited Singapore xxxxxx0350 Changpeng Zhao (80%) Guangying Chen Adrian Rhui Keong Darren Makarem BN KZ Technologies Limited Kazakhstan xxxxxx8810 Changpeng Zhao Guangying Chen Anton Keen Cyper Technologies SDN BHD Malaysia xxxxxx0378 Changpeng Zhao Guangying Chen Adrian Rhui Keong Darren Makarem UAE BV Investment UAE Management Limited BWIN Private Limited Singapore Changpeng Zhao * At least for one of several acocunts and for some points during the relevant period


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