Assessment of Civil Money Penalty Against BitMEX Entities for BSA Violations

UNITED STATES OF AMERICA
FINANCIAL CRIMES ENFORCEMENT NETWORK
DEPARTMENT OF THE TREASURY
IN THE MATTER OF: )
)
)
) Number 2021-02
HDR Global Trading Limited, )
100x Holdings Limited, )
ABS Global Trading Limited, )
Shine Effort Inc. Limited, )
HDR Global Services (Bermuda) Limited ) d/b/a BITMEX ) ______________________________________ ) ASSESSMENT OF CIVIL MONEY PENALTY
I. INTRODUCTION
The Financial Crimes Enforcement Network (FinCEN) has determined that grounds exist to assess a civil money penalty against HDR Global Trading Limited, 100x Holdings Limited, ABS Global Trading Limited, Shine Effort Inc. Limited, and HDR Global Services (Bermuda) Limited, which operate as an integrated, common enterprise doing business as BitMEX (collectively, BitMEX or Respondents) pursuant to the Bank Secrecy Act (BSA) and regulations issued pursuant to that Act.1 Without admitting or denying any factual or legal findings or conclusions herein, BitMEX has consented to the assessment of a civil money penalty and entered into a CONSENT TO THE ASSESSMENT OF CIVIL MONEY PENALTY (CONSENT) with FinCEN. Pursuant to the CONSENT, BitMEX agrees to pay a civil penalty in the amount of $100 million and to comply with the Undertakings set forth below. The CONSENT is incorporated into this ASSESSMENT OF CIVIL MONEY PENALTY (ASSESSMENT) as if fully set forth herein.

1. The BSA is codified at 12 U.S.C. §§ 1829b, 1951-1959 and 31 U.S.C. §§ 5311-5314, 5316-5336.
   Regulations implementing the BSA appear at 31 C.F.R. Chapter X.