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Binance & Russia: Openness, Transparency and Honesty

2022-04-25

In business media, crypto content performs extremely well. As the market leader, Binance is used to being headline news. Sometimes we may disagree with how we or crypto is portrayed, but more often than not, journalists work with us to educate readers.

Like any company, we make mistakes, and it’s the media’s job to hold us accountable. However there are times when media seek to provide a false narrative, and a recent article by Reuters has sought to portray - falsely - that Binance has close ties with FSB controlled agencies and Russian regulators. 

We don't expect news coverage to always be positive, or even balanced. But we expect it to be fair and accurate. In this case the article has been carefully written with a narrative in mind that provides just enough balance possible to try to avoid a legal complaint.

Let’s set the record straight: 

  • Suggestions that Binance shared any user data, including Alexei Navalny, with Russian FSB controlled agencies and Russian regulators are categorically false.

  • Indeed, Alexi Navalny's chief of staff Leonid Volkov himself pointed out the inconsistencies in the Reuters article on this point. According to Coindesk:

Navalny's chief of staff Leonid Volkov, who has been managing the fundraising campaign, told CoinDesk he doesn't believe Binance actually shared Navalny donors' data with Fordinmonitoring. "I believe Reuters was wrong. there are also multiple inconsistencies in the article.Coindesk add:

As an example of such inconsistency, Volkov mentioned that in April 2021, Binance did not require verification for all Russian users. The exchange, indeed, made KYC obligatory for Russian users in August 2021, meaning that before that, they could buy small amount of crypto and donate them to Navalny without giving their personal data to Binance at all.

  • Prior to the war, Binance’s engagement in Russia was no different from that of any other international organization - from banks to burger restaurants. 

  • Like every other blockchain company with users in Russia, prior to the War with Ukraine, Binance was advocating for Russia to develop an effective crypto regulatory framework - an effort we are undertaking in every market we operate in.

  • As soon as the war started, we stopped working in Russia. Instead, we implemented sanction requirements. Today, as far as we know, Binance is the ONLY crypto exchange in the world to implement the latest package of sanctions imposed by the European Union aimed at Russian account holders.

  • As an example,  Binance blocked several accounts linked to relatives of senior Kremlin officials in response to Russia’s invasion of Ukraine, including:

    — Polina Kovaleva, the stepdaughter of Foreign Minister Sergei Lavrov 

    — Elizaveta Peskova, the daughter of President Vladimir Putin’s spokesman Dmitry Peskov

    — Kirill Malofeev, the son of Konstantin Malofeev

  • We also donated time and $10M+ to the humanitarian effort to help Ukrainians in desperate need, a move recognized and appreciated - in person over Zoom with CZ - by Mykhailo Fedorov Minister of Digital Transformation of Ukraine.

  • On the specific matter of not sharing data - today, any government or law enforcement agency in the world can request user data from Binance as long as it is accompanied by the proper legal authority. In fact, we have developed a landing page specifically for this purpose which has been in place for over one year which is used by leading law enforcement agencies from around the world. Russia is no different.  Fulfilling disclosure obligations to the authorities in each jurisdiction is a large part of becoming a regulated business and Binance fulfills its legal obligations.

  • Binance reserves the right to reject law enforcement requests should they not stand up to legal scrutiny; this applies to all jurisdictions including Russia. This is the same as any leading bank, financial institution or multinational company. 

  • Binance has engaged with the Russian government in the very same way that it engages with other jurisdictions such as in Europe, the Middle East, Latin America and Asia-Pacific – these are legal engagements for the purposes of advocating for appropriate digital asset regulations.

  • And, to be clear. Binance has not sought to actively assist the Russian state in its attempts to investigate Alexi Navalny; indeed the prosecution case concerning Navalny noted that no donations that were the subject of investigation related to digital currencies. To say so is materially inaccurate.

Unfortunately, Reuters, one of the most esteemed and trusted news agencies, published this article that completely contradicts the reputation this outlet has built over the years and is not representative of our experience working with countless other journalists in their organization.

To this end, we will be writing a formal complaint to Reuters under their own editorial code as stated:

  • Reflecting reality in that it can be tempting for journalists to “hype” or sensationalize material, skewing the reality of the situation or misleading the reader or viewer into assumptions and impressions that are wrong and potentially harmful and;

  • Freedom of bias in that Reuters must always strive to be scrupulously fair and balanced. Allegations should not be portrayed as fact; charges should not be conveyed as a sign of guilt. We have a duty of fairness to give the subjects of such stories the opportunity to put their side.

Therefore, we have published our email exchange with the authors of that article below to let the community decide.

What you will find is that we spent weeks tracking down answers to every one of their 29 questions, only to have the parts of those answers that contradicted their narrative ignored.

To this end, here is the full email exchange with Reuters that we’re publishing in the spirit of full disclosure.

—----------------------------

От: Berwick, Angus (Reuters) 

Date: пн, 4 апр. 2022 г. в 19:43

Subject: Reuters article on Binance in Russia

To: gleb

Dear Mr Kostarev, 

I’m a reporter with Reuters based in London. Reuters is currently reporting an article about Binance’s operations in Russia. With my Reuters colleague Tom Wilson, we have been researching how Binance developed its significant market in Russia, how it has built ties with Russian government agencies, and how the war in Ukraine has affected Binance’s Russia business.

Our reporting, based on interviews with people familiar with Binance’s operations in Russia, indicates that Binance has played an important role in advising state agencies on the development of a regulatory framework for cryptocurrencies in Russia. Our reporting indicates that, under the proposed crypto law, Binance has agreed with Russia’s Financial Intelligence Unit, Rosfinmonitoring, to set up a local unit in Russia through which authorities can request client data. 

We would like to discuss our reporting with you so that we can reflect your and Binance’s positions in the article, and to ensure our reporting is accurate. As such, we would like to ask if it would be possible to arrange an interview with you on Binance’s Russia business.

Best regards,

Angus Berwick

====

From: Patrick Hillmann

Sent: Tuesday, April 12, 2022 12:55 AM

To: Berwick, Angus (Reuters)

Subject: Re: [EXT] Fwd: Reuters article on Binance in Russia

Angus and Tom,

Again, thanks for reaching out. It's a shame that Reuters is once again unwilling to allow an off-the-record conversation from taking place, as there is quite an interesting story that should be told here, but we simply can't share it without putting our peoples' lives in danger. I want to help you guys write a more accurate story. But I'm not certain what better reason there could possibly be for a preliminary off-the-record discussion than me being very clear that it is a concern regarding the safety and security of our people. I just don't understand what Reuter's bar is here? 

Again, it is starting to feel like we are simply a target that you are looking to beat publicly, rather than a piece of a story that you are trying to illuminate.

We have provided answers to as many of these questions as possible. Not sure who your source is, but they are very clearly making massive leaps to conclusions and/or are purposely misleading you in order to attack us for commercial purposes. I would sincerely hope that you are not sourcing this story with competitors of ours in the industry? Regardless of whether they are former employees or partners. Obviously, you would note that sort of commercial interest with your source, correct?

On that note, while you didn't mention any of the recent false accusations that the CEO of our largest competitor in Ukraine, Michael Chobanian of Kuna, has spread -- we have included a response and information that you can verify to demonstrate the length at which our competitors will go to falsely attack us using the press. 

Several lines of questioning in your email are beyond sensitive and could needlessly put the lives of a number of our employees at risk. Our legal counsel will be reaching out to ensure you understand the gravity of the issues you are juggling. 

We hope that you will handle this inquiry with the highest level of integrity.

Best,

Patrick

------------------

1. Data from CryptoCompare shows Binance is now processing over 80% of rouble-to-crypto trades…

This data is inaccurate and we do not comment on external data projections. We can, however, share that we are leading the industry in actively ensuring compliance with all sanction regimes. We will continue to aggressively comply with any and all financial sanctions by U.S. and international authorities.

2. Binance, in 2019, partnered with Advcash…

Following the initial round of western sanctions, we set out to proactively audit each and every third-party provider in the region, including Advcash. As a result of this risk-based approach, we have terminated a number of providers, including Garantex, who would later be officially sanctioned weeks after Binance had already proactively terminated them. 

3. In late 2020, Binance, in statements on its Telegram group for Russian users…

The lawsuit was dismissed on procedural grounds because Binance was never notified.

4. Mr Zhao has said publicly he is sad and angry about the humanitarian crisis in Ukraine…

CZ has been very clear on his position. Refer to CZ’s CNN interview here and blog entry here.

5. Mr Kostarev, in a message to an associate outside the company, said the war and sanctions…

The war in Ukraine and the resulting Russian economic crisis have deeply affected everyday Russian citizens and limited their access to basic financial tools to sustain their everyday living. Adoption of crypto may be accelerated amongst working-class Russian citizens who aren’t under sanctions as they look for alternative means to pay for goods and services, or receive basic financial support from family abroad.

6. Mr Zhao has said Binance would block sanctioned individuals, but would not unilaterally freeze millions

Binance Angels are volunteers, similar to docents, and therefore not employees and certainly not official spokespeople for the company.

Binance believes it would be unethical for a private organization to decide unilaterally to freeze millions of innocent users' accounts, which they rely on to pay for food, shelter, and healthcare. If western governments want to expand the scope of their economic retributions to include everyday Russian citizens, they alone have that power.

However, similar to more traditional financial institutions like Citibank, we have taken the steps necessary to ensure we take action against those that have had sanctions levied against them while minimizing the impact to innocent users. Should the international community widen those sanctions further, we will apply those aggressively as well.

Crypto is one of the few stable financial tools that working-class Russian civilians have to sustain their livelihood or attempt to flee and start a new life elsewhere. In fact, when Russians convert the ruble to crypto it weakens the ruble, weakening Russia’s financial power. Refer to CZ’s blog here.

7. Since the war began, Binance has drawn praise…

Before the Russian invasion of Ukraine, Binance had been participating in traditional lobbying efforts as is common for any company in countries they operate in. However, Binance has never met with nor communicated with Mr. Yakubovsky, his staff, or his party directly or indirectly. His opinions are his own and do not seem to be shared by the Russian government as evidenced by the Central Bank’s move to ban all crypto.

8. Russia’s parliament is currently considering a draft law to regulate cryptocurrencies…

Before the invasion of Ukraine, Binance was broadly supportive of legislation that would bring greater clarity to regulation in Russia. However, most legislation that Binance was aware of is likely no longer applicable given sanctions that many Russian banks are under due to the war.

9. People involved in the discussions on the law’s regulation say the Russian government wants to accelerate…

We are not aware of proposals to accelerate this law. These proposals may no longer be applicable or effective in the current situation and given the sanctions that many Russian banks are under due to the war.

10. In February 2021, Alexei Navalny’s Anti-Corruption Foundation…

No comment.

11. After the foundation’s fundraising, our reporting indicates the FSB…

No, Binance was never made aware of this, nor were we ever contacted by Russian authorities regarding Alexei Navalny.

12. The Anti-Corruption Foundation’s financing was a core part…

Binance is a blockchain company, therefore we aren’t qualified to provide meaningful comment here other than to say that the wrongful imprisonment of human beings is one of the worst crimes that authorities in power can commit. 

13. Russia’s financial intelligence unit Rosfinmonitoring has designated…

We have not had enough interaction with that organization to agree or disagree with that characterization. We were invited to participate in a working group with Rosfin, but decided not to proceed. We have zero ties to this organization.

14. In April 2021, Mr Kostarev met with Russia’s financial intelligence unit, Rosfinmonitoring, to discuss how cryptocurrency 

This is NOT an accurate account of events.

Before the war in Ukraine, we were actively seeking compliance in Russia as we are in all other countries. To be compliant with the proposed framework, Binance would be required to have a local entity under the supervision of the regulators, as is the case in all countries with similar regulatory requirements. 

Compliance with regulation requires that businesses respond to appropriate requests from regulators and law enforcement agencies. Like any financial institution, in cases where user data is requested, Binance has an internal process to assess the suitability of the request and the requirement to share data. This process is applied uniformly to all requests from all law enforcement agencies worldwide, including the FBI, Interpol, Europol, etc. 

The review process includes a stringent vetting process of the information being requested. However, we placed certain restrictions on law enforcement requests originating from certain jurisdictions, including Russia. Binance will never share data without a legitimate law enforcement request and reserves the right to decline when there is no legal purpose served by its release or flaws in the investigative approach leading to it. 

The investigations team, composed of former senior agents from the IRS, FBI, Europol, etc., handles these requests and assists law enforcement investigations. This team is composed of the top experts in the financial crime and anti-money laundering industry, including the case agents who led the Hydra Marketplace investigations and the shut down of BTC-e bitcoin exchange. These investigations are some of the most significant takedowns of Russian cybercriminals on record.

15. Our reporting indicates that Binance was invited to the meeting with Rosfin by a Russian non-profit organisation…

This is patently false. We were invited to participate but decided not to proceed. We have zero ties to this organization. 

16. In September 2021, Rosfin sent Binance a questionnaire, which we reviewed, seeking more information…

Binance takes its compliance obligations seriously and welcomes opportunities to consult with regulators. In this instance, Rosfin’s initiative failed to bear fruit as evidenced by the Central Bank’s decision to push to ban crypto. 

17. After Russia’s central bank governor, Elvira Nabiullina, voiced opposition to regulating crypto…

Before the Russian invasion of Ukraine, Binance had been participating in lobbying efforts, as is common for any company seeking to ensure their perspective on potential legislation is heard. Ultimately, these efforts were not successful and the Central Bank did announce its intention to ban crypto. 

18. In February, the Russian government approved a plan for crypto regulation, backed by agencies…

This is a reckless mischaracterization of Mr. Kostarev’s tweet, it is clear from the context that he was referring to the fact that the proposed ban had been seemingly dropped.

19. Our reporting indicates that at least one other cryptocurrency exchange declined to agree…

Please refer to response #14. No, we were not aware of this. Binance has strict policies and procedures to assess incoming data sharing requests including from law enforcement agencies. Data only can go back to 4-1-2020, 1,094 total requests from Russia, 3 directly from FSB, 1 directly from Rosfin. 

20. Mr Navalny’s chief of staff, Leonid Volkov, told us that if this regulatory framework…

Please refer to response #14. No, we were not aware of this. Binance has strict policies and procedures to assess incoming data sharing requests including from law enforcement agencies.

21. Mr Zhao has said that Binance works with law enforcement worldwide to protect users…

It is absolutely false that Binance refuses to share data with law enforcement agencies making legitimate requests, we treat all enquiries equally and assess them according to our standard policies and procedures. We are the most active participant in the industry in working with law enforcement as evidenced by our recent invitation to join the NCFTA. You can learn more about that here

Today, we participate in law enforcement working groups targeting ransomware, human trafficking, money laundering, and nation-state hacking. I know that we shared this with you previously and that it was ignored, but it’s critical to point out for your readers that Binance leads the industry in collaborating with law enforcement to develop best practices, mitigate/thwart new methods of criminality and prevent illicit proceeds from entering the marketplace

  Examples of some recent public outcomes can be seen as here:

1.     Binance Helps Take Down Cybercriminal Ring Laundering $500M in Ransomware

2.     Binance Helped UK Police Investigate Criminal Involved in $50 Million Fraud

3.     Binance Teamed Up With US Law Enforcement, Took Down Suspected Money Launderers

We invested considerable resources to build the industry’s largest, most prestigious cybersecurity and digital forensics team on the globe with over 120 former leading investigators from organizations including the US Secret Service, FBI, IRS, and Europol to name just a few. We’re proud to say that we have cleared multiple external anti-money laundering (AML) audits -- a strong validation of our current AML controls and partnerships. We have worked hard to build a robust compliance program that incorporates anti-money laundering principles and tools used by financial institutions to detect and address suspicious activity. Recently, we have partnered on working groups and seminars with notable anti-crime organizations such as the United Nations Office on Drugs and Crime (UNODC) and Interpol this year, and there are many more that we can't discuss publicly at this time.

In Regards to Recent Coverage of Unsubstantiated Claims Made by Michael Chobanian, CEO of Kuna Exchange:

Michael Chobanian’s exchange, Kuna, is one of Binance’s largest competitors in the region. Three years ago, Binance was in talks with Mr. Chobanian to explore a partnership with Kuna. Binance decided not to proceed with that partnership after remarks were made by Mr. Chobanian on a Telegram channel that offended a number of our employees. Mr. Chobanian was not pleased with that outcome.

We have tried to assume best intent with Mr. Chobanian, particularly given the brutal assault that his homeland is currently under. However, it has become apparent that Mr. Chobanian is more interested in using the current crisis to manipulate media to attack his largest competitor for financial gain.

Furthermore, a simple call to a leading blockchain analyst firm, such as Chainalysis, will confirm that Kuna continues to service the Russian market and allow sanctioned transactions and users to operate on his exchange. Furthermore, Kuna has a history of partnering with some of the industry’s most notorious bad actors, including Chatex, as evidenced here. 

One of Chobanian’s many blatant lies includes that we have not made good on our commitments to provide aid to the people of Ukraine. We have committed $10 million to Ukraine humanitarian efforts with under $8 million already distributed to the UNHCR, UNICEF, People in Need, iSans, Palianystia, Rotary Club Kyiv International, and Truhoma. We also launched a crowdfunding platform, Ukraine Emergency Relief Fund, to allow people to donate crypto to help provide emergency relief to refugees. More than $11 million has been raised with an additional $6 million contributed directly by Binance.Donation distribution details are listed below and can be verified:

=====


On Tue, Apr 12, 2022 at 6:19 AM Berwick, Angus (Reuters) wrote:

Hi Patrick,

Thank you for your response – we appreciate that you took the time to answer our questions in detail. There are a few points that we would like to follow up on, particularly those relating to the accuracy of our reporting. We would like to schedule a call today so you have the opportunity to expand on those points. Given Reuters' commitment to reflecting as fully and as accurately as possible the positions of all parties mentioned in our stories, we would like to talk on-the-record. If you wished to speak off-the-record about specific issues during the call, we would be happy to consider that at the time.

We would also, again, like to request an interview with Gleb, so that he can share his views with us directly.

Best regards,

Angus Berwick

====

From: Patrick Hillmann

Sent: Tuesday, April 12, 2022 2:13 PM

To: Berwick, Angus (Reuters)

Subject: Re: [EXT] Fwd: Reuters article on Binance in Russia

Hey Angus,

I'd be willing to offer an off-the-record call with you and the editor on this piece tomorrow and we could discuss providing additional comment on the record after that call.

We spent the last five days conducting an investigation which included having our internal audit team review 1000s of employee emails, calendars, and interviews with 10 employees. As a result, we have given you a comprehensive response to each of your questions.

To be frank, the facts are perfectly clear and we've provided very specific, informed answers. I'm sorry if your sources have taken you down a rabbit hole, but unfortunately, they are simply wrong. We are 100% confident in our responses without equivocation.  

And from a personal perspective having worked in government affairs my entire career, the idea that a foreign-based company has any sort of meaningful influence over the Russian government is honestly laughable -- as evidenced by the aggressive anti-crypto stance that the Russian government has taken in the run-up to and following the Ukraine conflict. 

Whoever told you otherwise has a VERY active imagination.

===

On Tue, Apr 12, 2022 at 10:17 AM Berwick, Angus (Reuters) wrote:

Hi Patrick,

Thank you for offer. We have to decline it, as we are looking for on-record responses. These are the points we would like further clarity on. We’d be grateful for your response to these questions by the end of tomorrow.

  • You said Binance has “zero ties” to Rosfinmonitoring. We have reviewed text messages from Mr Kostarev showing he met with Rosfin and was in communication with Rosfin during 2021. What do you mean when you refer to “zero ties”?

  • You said Binance was “invited to participate in a working group with Rosfin, but decided not to proceed.” Does this refer to the April 2021 meeting we detailed? What was the purpose of this working group and why did Binance decide not to proceed?

  • On point 14, you said “This is NOT an accurate account of events.” Could you please describe how this account is inaccurate as your response does not specify?

  • You said Binance has “zero ties” to the non-profit Digital Economy Development Fund. The Fund’s website shows that Mr Kostarev chairs its committee on digital currencies. What do you mean when you refer to “zero ties”?

  • You said that “Rosfin’s initiative failed to bear fruit” due to the central bank’s decision to push to ban crypto. However, the Russian government later approved a plan for crypto regulation, backed by Rosfin, and the finance ministry consequently submitted a draft law. Which initiative do you consider did not “bear fruit?”

  • In point 9, you said that proposals "may no longer be applicable or effective in the current situation." Could you explain further why this would be the case?

  • You said that since April 2020 Binance has received 1,094 requests from law enforcement agencies in Russia, of which 3 were from FSB and 1 was from Rosfin. Which agency were the other 1,090 requests from? How did Binance respond to the requests from the FSB and Rosfin?

Additionally, we would be grateful for any comment that Binance may have on the following: According to a person with direct knowledge, by mid-2021, Binance’s trading volumes in Russia made it Binance's second-largest market globally after China, including among VIP clients.

Best regards,

Angus Berwick

===

From: Patrick Hillmann

Sent: Apr 13, 2022, 8:50 PM

To: Berwick, Angus (Reuters)

Subject: Re: [EXT] Fwd: Reuters article on Binance in Russia

Here you go, Angus.

Again, I want to officially flag for you again that your source is very clearly ill-informed... across the board. We provided very clear answers to your questions. Your last story on us was about 60% based in fact, 10% qualified but ultimately false leaps to conclusions, and 30% unadulterated fiction.

I swallowed it the last time, but we won't do that again here. We will take this issue to the court of public opinion if you choose to ignore the facts here. I don't care who your source is, they are wrong -- regardless of whether it is out of ignorance or malice.

I am trying to be professional and help you here.

1. You said Binance has “zero ties” to Rosfinmonitoring. We have reviewed text messages from Mr Kostarev showing he met with Rosfin and was in communication with Rosfin during 2021. What do you mean when you refer to “zero ties”?

We did not work with, collaborate, nor partner with that organization – full stop. We were invited to discuss our potential participation in a working group which we ultimately declined because it wasn’t aligned with our priorities as an organization. 

2. You said Binance was “invited to participate in a working group with Rosfin, but decided not to proceed.” Does this refer to the April 2021 meeting we detailed? What was the purpose of this working group and why did Binance decide not to proceed?

It would obviously be inappropriate for us to disclose conversations that we’ve had with law enforcement agencies. We declined to participate in that working group, so we wouldn’t be qualified to comment on the working group’s activities. 

3. On point 14, you said “This is NOT an accurate account of events.” Could you please describe how this account is inaccurate as your response does not specify? 

You specifically asked us, “Is this account of events accurate?” And our answer is very specifically “no.” 

Whoever shared this information with you lacks even a basic understanding of how our security team’s processes work. No single individual or department has access to nor can approve or share customer data externally, even with law enforcement. We have already explained this process ad nauseam. Please refer below:

Compliance with regulation requires that businesses respond to appropriate requests from regulators and law enforcement agencies. Like any financial institution, in cases where user data is requested, Binance has an internal process to assess the suitability of the request and the requirement to share data. This process is applied uniformly to all requests from law enforcement agencies worldwide, regardless of whether it’s the FBI, FSB, or the Evanston Police Department making the request.

The review process includes a stringent vetting process of the information being requested. However, we placed certain restrictions on law enforcement requests originating from certain jurisdictions, including Russia. Binance will never share data without a legitimate law enforcement request and reserves the right to decline when there is no legal purpose served by its release or flaws in the investigative approach leading to it.

The investigations team, composed of 120 former senior agents from the IRS, FBI, Europol, etc., handles these requests and assists law enforcement investigations. This team is composed of the top experts in the financial crime and anti-money laundering industry, including the case agents who led the Hydra Marketplace investigations and the shut down of BTC-e bitcoin exchange. These investigations are some of the most significant takedowns of Russian cybercriminals on record.

4. You said Binance has “zero ties” to the non-profit Digital Economy Development Fund. The Fund’s website shows that Mr Kostarev chairs its committee on digital currencies. What do you mean when you refer to “zero ties”? 

We have been clear that we have zero ties nor a working relationship with Rosfin.

The Digital Economy Development Fund is an independent organization that was also advocating for a more concrete regulatory framework in Russia prior to the Ukraine conflict and the Central Bank’s decision to push for a ban on all crypto.

5. You said that “Rosfin’s initiative failed to bear fruit” due to the central bank’s decision to push to ban crypto. However, the Russian government later approved a plan for crypto regulation, backed by Rosfin, and the finance ministry consequently submitted a draft law. Which initiative do you consider did not “bear fruit?”

A draft bill? You realize that a draft bill has to be submitted, voted on, and passed to take effect?

Please refer here:

https://www.coindesk.com/policy/2022/02/16/bank-of-russia-proceeds-with-digital-ruble-renews-push-for-crypto-ban/

And here:

https://news.bitcoin.com/cryptocurrencies-carry-systemic-risks-threaten-ruble-bank-of-russia-insists/

6. In point 9, you said that proposals "may no longer be applicable or effective in the current situation." Could you explain further why this would be the case? 

The war and resulting global sanctions enacted have made it virtually impossible for any platform to initiate or consider future plans in the region. Our priority is to protect users and ensure full sanction compliance.

7. You said that since April 2020 Binance has received 1,094 requests from law enforcement agencies in Russia, of which 3 were from FSB and 1 was from Rosfin. Which agency were the other 1,090 requests from? How did Binance respond to the requests from the FSB and Rosfin?

Just like traditional banks, we receive the most inquiries from local law enforcement – such as a local sheriff who is investigating a suspect in a case. These cases can range from petty theft to more serious charges, such as homicide. We obviously cannot discuss the specific details of these requests as they may involve active and ongoing investigations. You’ll have to reach out to the agencies to confirm.

8. Additionally, we would be grateful for any comment that Binance may have on the following: According to a person with direct knowledge, by mid-2021, Binance’s trading volumes in Russia made it Binance's second-largest market globally after China, including among VIP clients.

As a private organization, we don’t share our market data publicly.