Read the U.S. Treasury Department's 24-page order in detail.

Written by: KarenZ, Foresight News

The U.S. Treasury Department's restrictions on MEXC start with the transfer of funds between it and U.S. financial institutions.

On November 6, the Financial Crimes Enforcement Network (FinCEN) of the U.S. Treasury Department ordered U.S. financial institutions to stop transferring funds with MEXC Global. This ban will take effect 30 days after being officially published in the Federal Register.

FinCEN stated, from May 2021 to May 2026, MEXC facilitated at least $16.7 billion in fund flows related to sanction evasion, cyber crimes, and other suspected illegal activities. The 24-page order issued by FinCEN also provides more specific details regarding the investigation.

This measure is part of Operation Economic Outcast. The U.S. launched this operation on August 24, 2026, aiming to cut off revenue sources and cross-border funding networks that support the Iranian government through sanctions and financial restrictions. The targets include foreign entities identified by the U.S. as assisting Iran in evading sanctions. Digital assets are also a key area of focus.

This is no longer just an action against cryptocurrency exchanges. More importantly, the U.S. is attempting to incorporate the fund flows of cryptocurrency exchanges into its regulatory boundaries through the rules of the traditional financial system. For a globally operating exchange, the real risk may not only be fines or restrictions on operations in specific countries but also the gradual loss of the ability to connect with the global financial system.

Whom does this order initially constrain?

First, let's see who this order restricts.

FinCEN issued the administrative order based on Section 9714 of the Anti-Money Laundering Act concerning Russian activities, identifying MEXC Global as involved in illegal financial activities related to Russia and deeming it a foreign financial institution that needs to be monitored for money laundering risks.

However, its definition of MEXC Global is not limited to a company registered in Seychelles.

According to the footnote on the second page of the order, FinCEN specifically lists the following affiliated entities: Seychelles MEXC Global Ltd, MX Global Ltd; Estonia MEXC Estonia OÜ; Switzerland GIDA Technology AG; UK MXC Global Ltd; formerly registered in Singapore MEXC Global Foundation Ltd, MEXC Singapore Pte Ltd.

There are two details worth noting.

First, the aforementioned list is not exhaustive. FinCEN used "including but not limited to" phrasing, meaning that any other MEXC Global affiliated entities, branches, offices, and successor entities operating outside the U.S. that meet the definition of the order could also be included.

Second, U.S.-based MEXC Global affiliated companies, subsidiaries, branches, and offices are explicitly excluded from this definition of the order.

Additionally, FinCEN has specifically defined "Successor Entity": any entity that acquires all or part of the assets of MEXC Global, or continues to conduct its business under a new name, may be included.

In other words, simply changing the registered entity, transferring assets, or renaming does not necessarily allow one to evade this order.

So, who needs to enforce this?

The administrative order states that covered financial institutions may not send funds to MEXC Global, nor may they receive funds from MEXC Global.

The scope of financial institutions here is defined according to U.S. Federal Regulation 31 CFR 1010.100(t), including: banks, securities brokers and dealers, money services businesses (MSB), telegraph companies, eligible casinos and card clubs, entities supervised by state or federal banking regulatory agencies, futures commission merchants, commodity introducing brokers, and mutual funds, among others.

Thus, this does not simply require a particular U.S. bank to close its account with MEXC, but rather establishes a ban on fund transfers aimed at an entire category of U.S.-regulated financial institutions.

One should also note the effective date: as of November 7, the documents issued by FinCEN are still awaiting publication in the Federal Register. The order will take effect 30 days after official publication, with no preset termination date.

$16.7 billion: What funds networks is MEXC Global involved in?

$16.7 billion is the most eye-catching figure in this incident, but if it is only seen as a total amount, it would miss the truly valuable information in the administrative order.

FinCEN set the investigation time frame from May 2021 to May 2026, assessing that MEXC Global facilitated at least $16.7 billion in fund flows related to sanction evasion involving Russia, Iranian entities, North Korean money laundering networks, ransomware, and other cybercrime activities.

Transactions with sanctioned Russian exchanges have not yet ceased

Funds related to Russia are the core legal entry point of this administrative order.

FinCEN assessed that from May 2021 to May 2026, MEXC Global was involved in nearly $1.5 billion in fund flows related to sanction evasion concerning Russia, including $232 million in direct transactions with sanctioned entities from the U.S., EU, or UK.

The document specifically names two trading platforms: Garantex and Grinex.

In April 2022, the U.S. Treasury Department listed the Russian cryptocurrency exchange Garantex on the sanctions list, citing its provision of funding services to ransomware operators and other cybercriminals. In 2025, the successor entity, Grinex, appeared. FinCEN pointed out that Grinex was created by Garantex employees to continue transferring funds after Garantex was sanctioned.

However, more noteworthy is the subsequent flow of funds. According to FinCEN's analysis, after the relevant sanctions were publicly enforced, MEXC Global still conducted about $129 million in direct transactions with Garantex and approximately $4.1 million with Grinex. Moreover, these transactions continued until June 2026.

A7: A payment network connecting Russia, Iran, and North Korea

A7 is a payment service network that claims to have anti-sanction capabilities, operating through entities like Old Vector LLC, Garantex, Grinex, InDeFi Bank, and ExVed.

The U.S. Treasury believes this network not only helps Russian entities evade financial restrictions but also has connections to the Iranian Revolutionary Guard, North Korean affiliates, Iranian-backed armed groups, and cybercriminals.

On October 1, 2026, the U.S. Treasury already listed the A7 network as a significant transnational criminal organization and imposed sanctions.

The financial transactions between MEXC Global and the A7 network are a critical subject of this investigation.

FinCEN estimates that MEXC Global facilitated at least $26 million in transactions benefiting the A7 network and sent or received nearly $200 million related to the ruble-pegged stablecoin A7A5.

FinCEN also explicitly named the issuer of A7A5, Old Vector LLC, and its owner, Ilan Shor, both of whom are subject to OFAC sanctions.

Funding chain related to Iran: over 40 exchanges in direct dealings with MEXC

The data concerning Iran is also astonishing.

FinCEN estimates that from May 2021 to May 2026, MEXC Global was involved in nearly $2 billion in fund flows related to individuals associated with Iran or known or suspected terrorist organizations, with $1.87 billion in direct trading exposure tied to Iran.

Of that, over $1 billion came from direct transactions between MEXC Global and more than 40 identified Iranian cryptocurrency exchanges.

FinCEN also identified about $22 million related to transactions with the Central Bank of Iran, the Iranian Revolutionary Guard, and its Quds Force.

Additionally, about $36 million in transactions involved the Qassam Brigades and other Iranian-affiliated organizations sanctioned by the U.S. and UK in the Gaza region.

It is worth noting that MEXC's user agreements had previously prohibited individuals or entities from Iran from using the platform, but FinCEN believes these regulations have not effectively stopped the relevant transactions.

On the North Korean side: minor cases are also crucial

Regarding North Korea, FinCEN named a North Korean money launderer, Sim Hyon Sop.

The U.S. imposed sanctions on him back in April 2023 and publicly identified cryptocurrency addresses associated with him.

But FinCEN believes that between June and September 2025, MEXC Global still helped him receive approximately $350,000.

Cybercrime funding channels: over $1 million daily

In terms of cybercrime, the data is even larger.

From May 2021 to May 2026, at least $1.99 billion in funds from or flowing to illegal cybercrime entities passed through MEXC Global, averaging more than $1 million daily.

Of that, from January 2022 to July 2024, MEXC Global received over $37.9 million in suspected ransomware payments involving over 125 types of ransomware variants.

The document even pointed out that a frequently used ransomware-related deposit address on the platform received over $1.17 million during the relevant period.

This means that FinCEN's investigation is not only aimed at geopolitical sanction evasion but also involves various directions such as ransomware, dark web markets, fraud proceeds, and stolen funds.

Another larger funding chain: $13 billion in direct dealings with four UK-sanctioned exchanges

If the $16.7 billion reveals MEXC Global’s financial connections with various countries, organizations, and cybercrime entities, then another set of data in the order further directs the investigation towards direct dealings among cryptocurrency exchanges.

FinCEN also pointed out that from May 2018 to July 2026, MEXC Global had over $13 billion in direct dealings with at least four high-risk exchanges sanctioned by the UK.

This data has a noteworthy aspect: the transaction time span is longer. In other words, FinCEN's tracking of relevant transactions can date back to the early establishment of MEXC Global.

It should be specifically noted that there may be overlapping potential between the timeframes and transaction targets involved in the aforementioned funding statistics.

Why did the U.S. choose to cut off funding transfer channels?

The reason given by FinCEN is that simply increasing record-keeping, information collection, and reporting requirements would still allow the relevant funds to continue flowing; merely restricting bank agency accounts could not adequately prevent MEXC Global from indirectly accessing the U.S. financial system through other foreign financial institutions.

Therefore, FinCEN chose to prohibit fund transfers between relevant U.S. financial institutions and MEXC Global and explicitly included virtual currencies in this restriction.

However, considering that blockchain transfers are irreversible, FinCEN has also provided operational space for refusing cryptocurrency fund transfers in specific situations, allowing institutions to take measures based on the specific circumstances.

Which institutions/projects have already restricted MEXC? Who may follow suit?

This might be the most important part of the incident to continue tracking moving forward.

The U.S. order does not mean that all banks, payment companies, and cryptocurrency projects globally must immediately cease cooperation with MEXC.

However, once an exchange is designated as a primary focus by the U.S. Treasury, other financial service providers may also reassess the relevant risks.

Currently, two levels can be observed regarding the potential impact of this incident.

The first category: as mentioned, legally mandated U.S. financial institutions. This also includes regulated U.S. cryptocurrency service providers. For example, Coinbase, Inc., Kraken's U.S. business entity Payward Interactive, Inc., and Binance.US operating entity BAM Trading Services, Inc., all have disclosed their money services business identities in official materials.

The second category includes domestic and foreign institutions/projects that may adjust policies. Foreign exchanges, payment companies, custodians, and cryptocurrency card service providers that rely on U.S. financial institutions to handle relevant funds may strengthen source reviews, adjust funding paths, or restrict transactions. This is based on a risk assessment resulting from business reliance, and specific measures will depend on each company's announcements.

According to user feedback, Plasma has begun to indicate that MEXC transactions may be limited. Additionally, the new version of the Terms of Service effective November 6 stipulates more explicitly: Plasma prohibits users from transacting with wallet addresses, smart contracts, and agreements listed on the U.S. OFAC SDN list, UK sanctions list, CIMA-related lists, or marked by its blockchain analysis and compliance partner.

It is foreseeable that as U.S. financial channel restrictions gradually take effect, the pressure MEXC faces may extend beyond the U.S. market. What is truly worth watching is how many financial institutions and cryptocurrency infrastructure service providers will take proactive steps to delineate the boundaries of their funding interactions with MEXC.

How has MEXC responded?

MEXC stated in its official announcement that it is reviewing the FinCEN order with its legal and compliance team, engaging in constructive communication with regulators, and has initiated an independent review of anti-money laundering and sanction controls; the platform also stated that operations are normal and user assets are secure.

From a broader industry perspective, this incident signals another point of interest: as stablecoins, crypto payments, and cross-border settlements gradually enter the traditional financial system, whether exchanges can sustain the trust of banks, payment institutions, and financial infrastructures is becoming another important competitive factor.