Source commentary by Liu Honglin of Mankun Blockchain Legal Services, published by TechFlow on November 9, 2026, at 16:21:55 UTC+8.
Moving funds on-chain does not necessarily put them beyond compliance controls. Centrally issued dollar stablecoins can retain issuer powers to freeze tokens at particular addresses, creating a point of control even when users hold their own private keys.
That mechanism is central to Liu Honglin’s argument that U.S. enforcement, dollar-denominated tokens and traditional financial partnerships are drawing offshore crypto exchanges more deeply into the U.S.-led financial system. His article presents this as an interpretation of several enforcement and commercial developments—not as evidence of a single coordinated strategy.
USDT and the limits of on-chain independence
According to the article, Tether said on March 7, 2025, that it had helped the U.S. Secret Service freeze $23 million connected to Garantex-related transactions.
The distinction is between control of a wallet and control of the token contract. A private key allows its holder to initiate transactions, but USDT’s issuer retains administrative powers that can restrict transfers of the relevant tokens at frozen addresses.
Tether had announced a voluntary wallet-freezing policy in December 2023 covering activity associated with the Office of Foreign Assets Control’s Specially Designated Nationals and Blocked Persons List, including freezing wallets already listed.
For exchanges, the implication is narrower than saying that all blockchain activity is subject to the same controls: an offshore platform using centrally issued stablecoins must account for each issuer’s compliance policies and freezing capabilities. Operating outside the United States or accepting only crypto does not remove that dependency.
Garantex: restrictions reach infrastructure and tokens
Garantex illustrates how those dependencies can overlap with conventional enforcement. OFAC sanctioned the Russian exchange in April 2022. In March 2025, U.S., German and Finnish authorities seized domains and servers used by the platform. The U.S. Justice Department also announced charges against relevant operators and disclosed the freezing of more than $26 million in related funds.
That figure is separate from Tether’s statement about the $23 million freeze; the article does not establish whether the amounts overlap.
According to an August 2025 U.S. Treasury announcement cited in the source, successor platform Grinex took over part of Garantex’s business, with related arrangements also using the ruble-backed A7A5 token. The United States subsequently sanctioned Grinex and associated people and businesses.
Liu’s assessment is that replacement platforms and payment arrangements may allow activity to continue, but can bring recurring infrastructure costs, restrictions on financial partners and further enforcement exposure.
Binance: USDC integration and USD1 settlement
The source contrasts those restrictions with exchanges pursuing closer commercial ties to dollar-stablecoin issuers and mainstream finance.
In December 2024, Binance and USDC issuer Circle announced a strategic partnership. Binance would expand USDC use across products including trading and payments, and incorporate it into corporate treasury management. Circle would provide technical and liquidity support.
A different stablecoin featured in Binance’s financing. In 2025, Abu Dhabi investment institution MGX made a $2 billion minority investment in Binance. At a Dubai event that May, a World Liberty Financial co-founder announced that the investment would settle using the project’s USD1 stablecoin. The source identifies World Liberty Financial as connected to the Trump family.
These arrangements followed Binance’s November 2023 criminal and related enforcement settlements with U.S. authorities. Binance agreed to pay more than $4.3 billion, while Changpeng Zhao pleaded guilty and resigned as chief executive. Under the Treasury arrangements described in the source, Binance faced five years of compliance monitoring, including access to books, records and systems and checks on its commitments to exit the U.S. market.
The article also reports that Zhao received a presidential pardon from Donald Trump in October 2025. That pardon concerned Zhao’s relevant federal offenses personally; it should not be read as removing Binance’s corporate compliance obligations.
Traditional finance adds another route to integration
The source describes a parallel development at OKX. On March 5, 2026, New York Stock Exchange parent Intercontinental Exchange announced an investment valuing OKX at $25 billion. The investment amount was not disclosed, but ICE would receive a board seat.
The announced plans included licensing OKX spot crypto-price data for U.S.-regulated futures products. Subject to regulatory approval, OKX also planned to give users access to ICE U.S. futures and the NYSE’s tokenized-equities market.
This followed a February 2025 guilty plea by OKX operator Aux Cayes FinTech, a Seychelles entity, and an agreement to pay more than $504 million in penalties and forfeiture. Its independent compliance-consultant arrangement was to continue until at least February 2027.
MEXC and the cost of access
The article’s immediate backdrop was a November 6, 2026, FinCEN order prohibiting U.S. financial institutions from processing transfers involving MEXC. According to the official announcement as reported by the source, U.S. authorities determined that MEXC processed at least $16 billion linked to sanctions evasion, cybercrime and other activity involving Iran, North Korea and Russia between May 2021 and May 2026.
The order was to take effect 30 days after publication in the Federal Register. MEXC said deposits, withdrawals and trading remained normal, and that it was reviewing the order and preparing to engage regulators.
Liu’s broader conclusion is that access to banking, institutional customers and financial products increasingly comes with compliance conditions. Stablecoins add an on-chain dimension: they can expand dollar settlement across borders while retaining issuer-level controls. Their use does not, by itself, make an exchange independent of the financial and regulatory relationships behind those tokens.