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- Court Dismisses Terror Financing Lawsuit Against Binance, Zhao
Court Dismisses Terror Financing Lawsuit Against Binance, Zhao
Plus Cushman & Wakefield gets sued because its 401(k) plans don’t include ESG funds.
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Good morning! Here’s what’s up.

Clips ✂️
Binance, Zhao win dismissal of lawsuit by victims of 64 attacks
A federal judge on Friday dismissed a civil lawsuit seeking to hold Binance, the world’s largest cryptocurrency exchange, and founder Changpeng Zhao liable for transactions that allegedly helped terrorist groups conduct 64 attacks around the world.
U.S. District Judge Jeannette Vargas in Manhattan said the 535 plaintiffs, including victims and relatives of victims, did not plausibly allege that the defendants “culpably associated themselves with these terrorist attacks, participated in them as something they wanted to bring about, or sought by their actions to ensure their success.” […]
Vargas said that while Binance and Zhao may have been generally aware of the exchange’s role in terrorist financing, their only relationship to the FTOs was that “they, or their affiliates, had accounts on, and have transacted on, the Binance exchange in an arms’ length relationship.”
The judge also called the length of the plaintiffs’ 891-page, 3,189-paragraph complaint “wholly unnecessary” despite the “weighty” allegations. She said the plaintiffs may amend their complaint.
Lawyers for the plaintiffs did not immediately respond to requests for comment.
…My point here is not to endorse one theory or another; I think both theories are partly true and hard to untangle. My point here is just that some people believe that “ESG” is not about maximizing investor returns, and other people think that “ESG” is about maximizing investor returns.
If you think it’s not, you go to Texas and sue American Airlines for doing ESG. If you think it is about maximizing investor returns, though, you go find a company whose 401(k) plans don’t have ESG funds, and you go to Seattle and sue that company for not doing ESG. Here’s a lawsuit filed last week, in a Seattle federal court, against Cushman & Wakefield Ltd….
👉 The lawsuit against Cushman & Wakefield is here.
“The FCPA Reinforcement Act” Introduced In Senate
Despite the brief 118 day “pause” of FCPA enforcement in 2025 (during which various aspects of FCPA and related enforcement continued), corporate FCPA enforcement by the DOJ in 2025 was above certain recent prior years. (See here).
The past nine months has been one of most active periods of FCPA trials of individuals in the FCPA’s nearly 50 years. In September, there was an FCPA trial. In December, there was an FCPA trial. In February, there was an FCPA trial. Post-trial activity continues in some of these matters in which the DOJ remains steadfast in its positions.
Another FCPA trial is soon to begin…. […]
Despite the above facts, some insist that FCPA enforcement has stopped, slowed down, or changed.
This group now formally includes various Democratic Senators who recently introduced “The FCPA Reinforcement Act” in the Senate.
The short bill seeks to extend the statute of limitations going forward for criminal FCPA anti-bribery offenses to ten years.
At present, the FCPA’s anti-bribery provisions does not specifically contain a statute of limitations. Rather, the five year “catch-all” provisions in 18 USC 3282 (for criminal actions) and 28 USC 2462 (for civil actions) apply.
👉 The proposed FCPA Reinforcement Act is here.
Polymarket Enlists Palantir, TWG AI to Monitor Sports Bets
Polymarket is enlisting firms including Palantir Technologies Inc. to help police its sports contracts, according to people familiar with the matter, a move that comes as prediction markets face intense scrutiny over insider trading.
Palantir and TWG AI will help Polymarket identify, prevent and report suspicious activity, said the people, who asked not to be identified because the information isn’t public yet. Measures include screening against existing lists of participants already banned from sports betting, the people said.
The monitoring system will be used on a US-regulated venue that Polymarket is building out, one of the people said. Its main trading platform is situated offshore and does not accept US-based customers.

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