This article was first published on Deythere.
After receiving his presidential pardon last month, Binance founder Changpeng “CZ” Zhao says if any of the $4.3 billion his company paid to U.S. regulators gets returned to him, he plans to reinvest it in America.
While the so-called Binance refund proposal has sent speculations within the crypto community, legal experts said that it’s structurally complex and politically sensitive. The $4.3 billion didn’t go into just one account; the penalties were levied in many different deposits across many U.S. agencies, so getting that money back isn’t a simple matter.
The $4.3B Settlement Mosaic
The $4.3 billion that gets tossed around as a jumble of criminal and civil penalties, not a heavily fortified bank account to be reclaimed.
Under their agreements, Binance paid approximately have $4.316 billion as part of a criminal resolution, according to a regulatory filing and the Department of Justice.
But that was only part of the story. The settlement also included:
A $3.4 billion civil penalty from FinCEN (Financial Crimes Enforcement Network
A $968.6 million U.S. Treasury’s OFAC sanctions settlement
CFTC (Commodity Futures Trading Commission) fines of $2.7 billion, divided equally between disgorgement and punishment, as well as a personal fine from CZ of $150 million.
Because these pay-outs not only reached across multiple agencies, they can’t just be “refunded” en masse.
CZ’s Comments After the Pardon
After his pardon from President Trump on October 23, 2025, CZ addressed the question of recouping some of the $4.3M. On X, he described it as “delicate.”
He said he has yet to request a refund, but added:
“IF we get any refund, we will be investing that in America anyway, to show our appreciation.”
CZ presented this as a gesture, showing his thanks for the pardon and promise of US-based innovation.
Legal Hurdles to Any Refund
A presidential pardon doesn’t automatically transfer to a way for Binance to get the billions back, said legal experts.
The pardon is only effective for CZ himself; the corporate fines are not covered. This huge $4.3B settlement was paid by Binance as a corporation and not Zhao himself.
U.S. law holds that money already in the Treasury cannot simply be returned without a congressional appropriation. This is in accordance with long-standing legal standards that when money is in the U.S. Treasury, it’s public funds.
In the 19th-century case Knote v. United States, for instance, the Supreme Court held that refunded moneys must be paid only pursuant to general appropriation by law and not as a matter of executive action.
In other words, for Binance to recover any of that $4.3B, more than a presidential pardon would be required since it involves Congressional approval.
Political and Regulatory Implications
If Binance were to attempt to recover the funds, it risks opening a political can of worms:
The $4.3 billion fine was one of the largest ever levied on a crypto firm. A repayment would be viewed as undermining the US enforcement.
That money would have to be refunded by Congress passing a law appropriating those funds, which is a heavy lift.
Critics would see any refund as pay-to-play, particularly because Trump pardoned CZ. And indeed, there have been questions raised about political connections.
CZ said he would redeploy any refunded funds back into U.S. markets. That could be spun positively, but also raises questions about whether it helps politically connected US crypto ventures.
If a Refund Were Politically Feasible, What Would It Look Like?
It’s probably not going to happen that they get $4.3B back under other current laws but partial or modified relief may be doable, experts say:
The White House could bargain with DOJ and other agencies to soften existing compliance terms by, for example, shortening or narrowing the scope of the monitorship. Analysts have said that is legally possible.
There could be a congressional appropriation to enable the funds to be partially refunded, but that would require unprecedented, politically fraught actions.
Agencies could re-credit prior payments or construct future terms of penalties in a more beneficial way, thus relieving Binance’s burden without an actual refund.
In all instances, the “refund” would be partial or token, not full.
How the Crypto Industry Is Responding
The crypto industry is paying close attention. CZ’s Binance refund remarks have stirred controversy. Some see the reinvestment vow as a sincere commitment to US innovation, while others dismiss it as political posturing or an effort to curry favor.
But skepticism remains. Any effort to recover that money would have significant implications for accountability and the precedent it establishes for other crypto companies, critics including US lawmakers say.
Conclusion
CZ’s remarks about potentially investing a refund from Binance’s $4.3B settlement back into the US have led to one of the crypto industry’s most tantalizing what-ifs.
His comment is bold but the practicality of repatriating the money is complex as American laws limit reimbursements from the Treasury.
And even if Binance does manage to recover some money, it would likely be only a tiny portion and come only after a political and legislative battle.
Whatever happens next, it will shape the intersection of enforcement, clemency and crypto capital in America.
Glossary
Pardon: This is, in effect, a personal and direct presidential lifeline to someone convicted of crime.
Appropriation : In short, an appropriation is a law that Congress passes allowing the Treasury Department to give away big stacks of money.
Consent Order : When a company or person settles with the government, this is the official agreement they sign promising to stop doing what they did and pay some fines without admitting any guilt.
Clemency : Essentially, clemency is short for pardon, commutation or any kind of mercy that the law permits.
Monitorship: A regulatory monitor is an independent third-party person or group of persons who oversees a company to make sure it’s following the rules, for some set period of time.
Forfeiture : That is when the law takes someone’s property as a punishment for some crime or civil wrong the
Frequently Asked Questions About Binance Refund
Is CZ seriously asking for $4.3B Binance refund back after the pardon?
As he’s said publicly, he hasn’t even asked for a refund yet.
If a refund did come through would the money just go back to Binance?
No, because a lot of the settlement went to US agencies, and got deposited in the Treasury, it can only be handed out via a special congressional appropriation and can’t just be waved through by a pardon.
Why would CZ even reinvest the refunded cash into the US?
He said that if any money came back in, he’d reinvest it in America as a gesture of appreciation.
Could the legal settlement get renegotiated, especially with CFTC of FinCEN?
Possibly, but no guarantees. According to the experts, it could be up for review but it would likely be no easy feat.
Is returning such a large sum to Binance a risky move?
Absolutely, returning that kind of money to a powerful company like Binance would raise all sorts of questions about accountability and just how serious the regulatory authorities are about enforcing the law.
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