Audit log

Every state-changing event for BitMEX: moderation decisions on community submissions, plus corrections and updates from the news pipeline. URL-based decisions carry three independent witnesses — the original source, an Internet Archive snapshot taken at submission time, and a Solana memo signed by our publicly-disclosed publisher key.

1. #1publishby system:backfill

   2026-05-31 06:58:53Z
   Score: ? → ? (no score change)
   anchoranchored

   chain

   ●mainnet-betaslot 423,324,478

   sig

   27L8UBjfTa2L…sr2U5QGwcopyexplorer ↗

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   GUznHkcigTc1…JLD5qTpwcopysha256 → base58

   verifying row…full verify ↗

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   {"actor":"system:backfill","investigation_id":"1876f965-9dbe-4c95-8793-73c5838efe98","kind":"publish","page_slug":"bitmex","published_at":"2026-05-31T06:58:53.507Z","sequence_num":1,"snapshot":{"content_type":"investigation","entity_name":"BitMEX","sections":[{"content":"BitMEX was founded in January 2014 by Arthur Hayes, Ben Delo, and Samuel Reed, operating under the parent entity HDR Global Trading Limited. Hayes, a Wharton economics graduate who previously traded equity derivatives at Deutsche Bank and Citigroup in Hong Kong, co-founded the exchange to provide professional-grade Bitcoin derivatives trading. The exchange pioneered the perpetual swap contract — a derivative instrument with no expiry date — which became the most widely traded crypto derivative globally. By 2021, BitMEX reported average daily trading volumes exceeding $2 billion. The exchange was incorporated in the Seychelles and structured through a web of offshore entities to serve users globally.","heading":"Founding and Rise","severity":"low","sources":[{"credibility":2,"name":"BitMEX - Wikipedia","type":"other","url":"https://en.wikipedia.org/wiki/BitMEX"},{"credibility":2,"name":"Arthur Hayes (banker) - Wikipedia","type":"other","url":"https://en.wikipedia.org/wiki/Arthur_Hayes_(banker)"}]},{"content":"On October 1, 2020, the Commodity Futures Trading Commission filed a civil enforcement action against five HDR-affiliated entities and co-founders Arthur Hayes, Ben Delo, and Samuel Reed for operating an unregistered trading platform and violating multiple CFTC regulations. The complaint alleged that BitMEX offered off-exchange commodity futures and options transactions, acted as an unregistered futures commission merchant, and operated a swap execution facility without required registration. The CFTC found that BitMEX received over $11 billion in Bitcoin deposits and generated more than $1 billion in fees. Simultaneously, the U.S. Attorney for the Southern District of New York unsealed a criminal indictment charging Hayes, Delo, Reed, and Head of Business Development Gregory Dwyer with conspiring to violate the Bank Secrecy Act by willfully failing to establish, implement, and maintain an anti-money laundering program. Prosecutors alleged BitMEX had deliberately structured its operations to avoid U.S. regulatory requirements while knowingly serving U.S. customers.","heading":"CFTC and DOJ Charges (October 2020)","severity":"critical","sources":[{"credibility":1,"name":"CFTC Press Release 8270-20: CFTC Charges BitMEX Owners","type":"regulatory","url":"https://www.cftc.gov/PressRoom/PressReleases/8270-20"},{"credibility":2,"name":"CoinDesk: Crypto Trading Platform BitMEX Attempted to Evade US Regulations","type":"news","url":"https://www.coindesk.com/policy/2020/10/01/crypto-trading-platform-bitmex-attempted-to-evade-us-regulations-cftc-doj-charge"},{"credibility":2,"name":"Money Laundering Watch: CFTC and DOJ Charge BitMEX","type":"news","url":"https://www.moneylaunderingnews.com/2020/10/cftc-and-doj-charge-bitmex-and-executives-with-illegally-trading-in-digital-assets-and-ignoring-bsa-aml-requirements/"}]},{"content":"On August 10, 2021, U.S. District Court for the Southern District of New York ordered the BitMEX corporate entities to pay $100 million to resolve both CFTC and FinCEN civil charges. The penalty was split between the two agencies, with up to $50 million allocated to the CFTC and the remainder to FinCEN. An $80 million portion was payable immediately, with a further $20 million suspended pending completion of a suspicious activity report lookback review and independent consultant assessments of BitMEX's AML policies, procedures, and controls. FinCEN noted that BitMEX had processed more than $200 million in transactions connected to darknet markets or mixing services. The settlement represented FinCEN's first-ever enforcement action against a futures commission merchant. As part of the consent order, BitMEX was required to permanently bar U.S. persons from the platform, verify all active users, and maintain only non-customer-facing U.S. personnel.","heading":"$100 Million Civil Settlement (August 2021)","severity":"critical","sources":[{"credibility":1,"name":"CFTC Press Release 8412-21: Federal Court Orders BitMEX to Pay $100 Million","type":"regulatory","url":"https://www.cftc.gov/PressRoom/PressReleases/8412-21"},{"credibility":1,"name":"FinCEN: $100 Million Enforcement Action Against BitMEX","type":"regulatory","url":"https://www.fincen.gov/news/news-releases/fincen-announces-100-million-enforcement-action-against-unregistered-futures"},{"credibility":2,"name":"CoinDesk: BitMEX Announces $100M CFTC, FinCEN Settlement","type":"news","url":"https://www.coindesk.com/markets/2021/08/10/bitmex-announces-100m-cftc-fincen-settlement"}]},{"content":"All three co-founders ultimately pleaded guilty to one count each of violating the Bank Secrecy Act. Arthur Hayes pleaded guilty in February 2022 and was sentenced on May 20, 2022 to two years of probation with the first six months to be served under home detention, plus a $10 million criminal fine. Ben Delo also pleaded guilty in February 2022 and was sentenced on June 15, 2022 to 30 months of probation without home confinement, plus a $10 million fine. Samuel Reed pleaded guilty on March 9, 2022 and was sentenced on July 13, 2022 to 18 months of probation, described by the court as 'somewhat less culpable' than the other founders, plus a $10 million fine. Gregory Dwyer, Head of Business Development, pleaded guilty in August 2022 and was sentenced on November 16, 2022 to one year of probation and a $150,000 criminal fine. The CFTC separately ordered each of the three co-founders to pay $10 million in civil penalties, totaling $30 million across all three individuals. None of the defendants received prison time.","heading":"Guilty Pleas and Criminal Sentences","severity":"critical","sources":[{"credibility":1,"name":"CFTC Press Release 8522-22: Court Orders BitMEX Co-Founders to Pay $30 Million","type":"regulatory","url":"https://www.cftc.gov/PressRoom/PressReleases/8522-22"},{"credibility":2,"name":"CoinDesk: Former BitMEX CEO Arthur Hayes Sentenced to 2 Years Probation","type":"news","url":"https://www.coindesk.com/policy/2022/05/20/former-bitmex-ceo-arthur-hayes-sentenced-to-2-years-probation"},{"credibility":2,"name":"CoinDesk: BitMEX's Delo Will Not Face Prison After Guilty Plea","type":"news","url":"https://www.coindesk.com/business/2022/06/15/bitmexs-delo-will-not-face-prison-after-guilty-plea"},{"credibility":1,"name":"DOJ SDNY: Third Founder of Cryptocurrency Exchange Pleads Guilty","type":"regulatory","url":"https://www.justice.gov/usao-sdny/pr/third-founder-cryptocurrency-exchange-pleads-guilty-bank-secrecy-act-violations"},{"credibility":1,"name":"DOJ SDNY: High-Ranking Employee Pleads Guilty to BSA Violations","type":"regulatory","url":"https://www.justice.gov/usao-sdny/pr/high-ranking-employee-cryptocurrency-exchange-pleads-guilty-bank-secrecy-act-violations"}]},{"content":"On November 1, 2019, BitMEX exposed the email addresses of a substantial portion of its user base when the exchange sent a mass marketing email using the carbon copy (CC) field rather than blind carbon copy (BCC), rendering each recipient's address visible to all other recipients. BitMEX attributed the incident to a failure in its email distribution software. In response, the exchange reset passwords for all accounts lacking two-factor authentication that also held a balance, due to observed hostile login attempts following the disclosure. The incident drew criticism given the sensitivity of cryptocurrency exchange user data, which can expose holders to targeted phishing, SIM-swapping, and other attacks. Binance CEO Changpeng Zhao publicly urged BitMEX users who shared email addresses across platforms to change their credentials.","heading":"2019 Email Data Leak","severity":"medium","sources":[{"credibility":2,"name":"CoinDesk: BitMEX Exchange Exposes User Base in Email Mishap","type":"news","url":"https://www.coindesk.com/markets/2019/11/01/bitmex-exchange-exposes-user-base-in-email-mishap"},{"credibility":2,"name":"CoinDesk: BitMEX Says Quality Check Failure Led to Email Privacy Breach","type":"news","url":"https://www.coindesk.com/markets/2019/11/04/bitmex-says-quality-check-failure-led-to-email-privacy-breach"},{"credibility":2,"name":"Bitcoin Magazine: BitMEX Compromises User Data In Email Gaffe","type":"news","url":"https://bitcoinmagazine.com/culture/bitmex-compromises-user-data-in-email-gaffe"}]},{"content":"Following the October 2020 charges, HDR Global Trading Limited reorganized as the 100x Group, appointing Alexander Höptner, formerly CEO of German exchange Börse Stuttgart, as the new Chief Executive Officer in November 2020. Vivien Khoo had served as interim CEO during the transition period. BitMEX has stated it implemented a comprehensive compliance program since 2020 covering AML, KYC, and broader regulatory standards. In partnership with on-chain analytics firm Chainalysis, the exchange reported reducing its on-chain risk exposure by 88%, from 1.7% in 2019 to 0.2% in 2024. As of 2024, HDR Global Trading Limited operates as a Virtual Asset Service Provider under transitional provisions of the Seychelles Virtual Asset Service Providers Act 2024, pending a licensing decision by the Seychelles Financial Services Authority. BitMEX remains inaccessible to U.S. persons pursuant to the consent order and continues to operate in over 120 countries while explicitly excluding the United States, Russia, and several other restricted jurisdictions.","heading":"Corporate Restructuring and Compliance Overhaul","severity":"medium","sources":[{"credibility":2,"name":"CoinDesk: Parent of Troubled BitMEX Names Former Stock Exchange Chief Its New CEO","type":"news","url":"https://www.coindesk.com/markets/2020/12/01/parent-of-troubled-bitmex-names-a-former-stock-exchange-chief-its-new-ceo/"},{"credibility":3,"name":"BitMEX Blog: BitMEX Strengthens Compliance to Reduce Risk Exposure by 88%","type":"official","url":"https://blog.bitmex.com/compliance-transformation/"},{"credibility":3,"name":"BitMEX Regulatory Licences","type":"official","url":"https://www.bitmex.com/en/regulatory-licences"}]},{"content":"On March 28, 2025, President Donald Trump issued full pardons to Arthur Hayes, Benjamin Delo, Samuel Reed, and Gregory Dwyer, expunging their criminal convictions for Bank Secrecy Act violations. Simultaneously, Trump issued a pardon to HDR Global Trading Limited — the corporate entity — which was noted as a rare instance of a presidential pardon issued to a corporation. The pardons were issued more than two years after the founders completed or were serving their respective terms of probation. The pardon of the corporate entity was particularly notable given HDR had already paid its $100 million civil penalty. Critics, including Axios, characterized the pardons as part of a broader pattern of clemency toward white-collar defendants with connections to the cryptocurrency industry.","heading":"Presidential Pardons (March 2025)","severity":"high","sources":[{"credibility":1,"name":"CNBC: Trump Pardons Three BitMEX Crypto Exchange Co-Founders","type":"news","url":"https://www.cnbc.com/2025/03/28/trump-pardon-bitmex-crypto-exchange-money-laundering.html"},{"credibility":1,"name":"Bloomberg: Trump Pardons BitMEX Co-Founders Arthur Hayes, Benjamin Delo and Samuel Reed","type":"news","url":"https://www.bloomberg.com/news/articles/2025-03-28/trump-pardons-bitmex-co-founders-arthur-hayes-benjamin-delo-and-samuel-reed"},{"credibility":2,"name":"The Intercept: Trump Just Pardoned a Corporation?","type":"news","url":"https://theintercept.com/2025/04/02/trump-pardons-corporation-bitmex-crypto/"}]}],"sources_used":[{"name":"CFTC Press Release 8270-20: CFTC Charges BitMEX Owners","type":"regulatory","url":"https://www.cftc.gov/PressRoom/PressReleases/8270-20"},{"name":"CFTC Press Release 8412-21: Federal Court Orders BitMEX to Pay $100 Million","type":"regulatory","url":"https://www.cftc.gov/PressRoom/PressReleases/8412-21"},{"name":"CFTC Press Release 8522-22: Court Orders BitMEX Co-Founders to Pay $30 Million","type":"regulatory","url":"https://www.cftc.gov/PressRoom/PressReleases/8522-22"},{"name":"FinCEN: $100 Million Enforcement Action Against BitMEX","type":"regulatory","url":"https://www.fincen.gov/news/news-releases/fincen-announces-100-million-enforcement-action-against-unregistered-futures"},{"name":"DOJ SDNY: Third Founder of Cryptocurrency Exchange Pleads Guilty","type":"regulatory","url":"https://www.justice.gov/usao-sdny/pr/third-founder-cryptocurrency-exchange-pleads-guilty-bank-secrecy-act-violations"},{"name":"DOJ SDNY: High-Ranking Employee Pleads Guilty to BSA Violations","type":"regulatory","url":"https://www.justice.gov/usao-sdny/pr/high-ranking-employee-cryptocurrency-exchange-pleads-guilty-bank-secrecy-act-violations"},{"name":"CoinDesk: Crypto Trading Platform BitMEX Attempted to Evade US Regulations","type":"news","url":"https://www.coindesk.com/policy/2020/10/01/crypto-trading-platform-bitmex-attempted-to-evade-us-regulations-cftc-doj-charge"},{"name":"CoinDesk: BitMEX Announces $100M CFTC, FinCEN Settlement","type":"news","url":"https://www.coindesk.com/markets/2021/08/10/bitmex-announces-100m-cftc-fincen-settlement"},{"name":"CoinDesk: Former BitMEX CEO Arthur Hayes Sentenced to 2 Years Probation","type":"news","url":"https://www.coindesk.com/policy/2022/05/20/former-bitmex-ceo-arthur-hayes-sentenced-to-2-years-probation"},{"name":"CoinDesk: BitMEX's Delo Will Not Face Prison After Guilty Plea","type":"news","url":"https://www.coindesk.com/business/2022/06/15/bitmexs-delo-will-not-face-prison-after-guilty-plea"},{"name":"CoinDesk: BitMEX Exchange Exposes User Base in Email Mishap","type":"news","url":"https://www.coindesk.com/markets/2019/11/01/bitmex-exchange-exposes-user-base-in-email-mishap"},{"name":"The Block: BitMEX co-founder Benjamin Delo sentenced to 30 months probation","type":"news","url":"https://www.theblock.co/linked/152355/bitmex-co-founder-benjamin-delo-sentenced-to-30-months-probation-without-home-confinement"},{"name":"Bloomberg: BitMEX Co-Founder Arthur Hayes Sentenced to Two Years Probation","type":"news","url":"https://www.bloomberg.com/news/articles/2022-05-20/bitmex-co-founder-arthur-hayes-sentenced-to-two-years-probation"},{"name":"CNBC: Trump Pardons Three BitMEX Crypto Exchange Co-Founders","type":"news","url":"https://www.cnbc.com/2025/03/28/trump-pardon-bitmex-crypto-exchange-money-laundering.html"},{"name":"Bloomberg: Trump Pardons BitMEX Co-Founders","type":"news","url":"https://www.bloomberg.com/news/articles/2025-03-28/trump-pardons-bitmex-co-founders-arthur-hayes-benjamin-delo-and-samuel-reed"},{"name":"The Intercept: Trump Just Pardoned a Corporation?","type":"news","url":"https://theintercept.com/2025/04/02/trump-pardons-corporation-bitmex-crypto/"},{"name":"BitMEX Blog: Compliance Transformation","type":"official","url":"https://blog.bitmex.com/compliance-transformation/"},{"name":"BitMEX - Wikipedia","type":"other","url":"https://en.wikipedia.org/wiki/BitMEX"}],"summary":"BitMEX (Bitcoin Mercantile Exchange) is a cryptocurrency derivatives exchange founded in 2014 by Arthur Hayes, Ben Delo, and Samuel Reed that pioneered the perpetual swap contract and at its peak was one of the largest crypto derivatives platforms in the world. In October 2020, the CFTC and DOJ charged the exchange and its co-founders with operating an unregistered trading platform and willfully failing to implement anti-money laundering and know-your-customer programs in violation of the Bank Secrecy Act. All three co-founders subsequently pleaded guilty, the exchange paid a $100 million civil settlement, and in March 2025 the founders and the corporate entity received presidential pardons from Donald Trump.","timeline":[{"date":"2014-01-01","event":"BitMEX (Bitcoin Mercantile Exchange) founded by Arthur Hayes, Ben Delo, and Samuel Reed under HDR Global Trading Limited.","source":"BitMEX - Wikipedia","source_url":"https://en.wikipedia.org/wiki/BitMEX"},{"date":"2019-11-01","event":"BitMEX accidentally exposes email addresses of a large portion of its user base by using CC instead of BCC in a mass marketing email.","source":"CoinDesk: BitMEX Exchange Exposes User Base in Email Mishap","source_url":"https://www.coindesk.com/markets/2019/11/01/bitmex-exchange-exposes-user-base-in-email-mishap"},{"date":"2020-10-01","event":"CFTC files civil enforcement action against BitMEX entities and co-founders Hayes, Delo, and Reed for operating an unregistered derivatives trading platform and failing to implement AML/KYC procedures. DOJ simultaneously unseals criminal indictment charging the same three plus Gregory Dwyer with BSA violations.","source":"CFTC Press Release 8270-20","source_url":"https://www.cftc.gov/PressRoom/PressReleases/8270-20"},{"date":"2020-11-30","event":"BitMEX parent restructures as 100x Group; Alexander Höptner appointed new CEO, replacing interim CEO Vivien Khoo.","source":"CoinDesk: Parent of Troubled BitMEX Names a Former Stock Exchange Chief Its New CEO","source_url":"https://www.coindesk.com/markets/2020/12/01/parent-of-troubled-bitmex-names-a-former-stock-exchange-chief-its-new-ceo/"},{"date":"2021-08-10","event":"U.S. District Court orders BitMEX entities to pay $100 million civil penalty split between CFTC and FinCEN to resolve charges of operating an unregistered platform and BSA violations.","source":"CFTC Press Release 8412-21","source_url":"https://www.cftc.gov/PressRoom/PressReleases/8412-21"},{"date":"2022-02-01","event":"Arthur Hayes and Benjamin Delo each plead guilty to one count of violating the Bank Secrecy Act.","source":"CoinDesk: Former BitMEX CEO Arthur Hayes Sentenced to 2 Years Probation","source_url":"https://www.coindesk.com/policy/2022/05/20/former-bitmex-ceo-arthur-hayes-sentenced-to-2-years-probation"},{"date":"2022-03-09","event":"Samuel Reed pleads guilty to one count of violating the Bank Secrecy Act.","source":"DOJ SDNY: Third Founder of Cryptocurrency Exchange Pleads Guilty","source_url":"https://www.justice.gov/usao-sdny/pr/third-founder-cryptocurrency-exchange-pleads-guilty-bank-secrecy-act-violations"},{"date":"2022-05-20","event":"Arthur Hayes sentenced to two years of probation with six months of home detention and a $10 million criminal fine.","source":"CoinDesk: Former BitMEX CEO Arthur Hayes Sentenced to 2 Years Probation","source_url":"https://www.coindesk.com/policy/2022/05/20/former-bitmex-ceo-arthur-hayes-sentenced-to-2-years-probation"},{"date":"2022-06-15","event":"Benjamin Delo sentenced to 30 months of probation without home confinement and a $10 million criminal fine.","source":"CoinDesk: BitMEX's Delo Will Not Face Prison After Guilty Plea","source_url":"https://www.coindesk.com/business/2022/06/15/bitmexs-delo-will-not-face-prison-after-guilty-plea"},{"date":"2022-07-13","event":"Samuel Reed sentenced to 18 months of probation and a $10 million criminal fine.","source":"MLex: Somewhat less culpable BitMEX co-founder sentenced to US probation","source_url":"https://www.mlex.com/mlex/articles/2154122/somewhat-less-culpable-bitmex-co-founder-sentenced-to-us-probation"},{"date":"2022-08-08","event":"Gregory Dwyer, former Head of Business Development, pleads guilty to violating the Bank Secrecy Act.","source":"CoinDesk: BitMEX Executive Pleads Guilty to Violating Anti-Money Laundering Act","source_url":"https://www.coindesk.com/policy/2022/08/08/bitmex-executive-pleads-guilty-to-violating-anti-money-laundering-act"},{"date":"2022-11-16","event":"Gregory Dwyer sentenced to one year of probation and a $150,000 criminal fine.","source":"Willkie Compliance Concourse: Fourth BitMEX executive sentenced","source_url":"https://complianceconcourse.willkie.com/articles/news-alerts-2022-11-november-20221122-fourth-bitmex-executive-sentenced-af/"},{"date":"2025-03-28","event":"President Trump issues full pardons to Arthur Hayes, Benjamin Delo, Samuel Reed, Gregory Dwyer, and the corporate entity HDR Global Trading Limited, expunging all criminal convictions related to the BSA case.","source":"CNBC: Trump Pardons Three BitMEX Crypto Exchange Co-Founders","source_url":"https://www.cnbc.com/2025/03/28/trump-pardon-bitmex-crypto-exchange-money-laundering.html"}]},"v":1}

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   python -m src.verify_decision 9b471b33-e95e-44c3-8212-a2b0a04c629ecopy