Michigan Dissolves Prohibition Order for Changpeng Zhao

MI DIFS Directors Orders

Filed March 16th, 2026

Detected March 19th, 2026

Summary

The Michigan Department of Insurance and Financial Services (DIFS) has dissolved a prohibition order against Changpeng Zhao. The order, originally issued on August 28, 2024, is dissolved due to a full and unconditional presidential pardon granted to Zhao on October 21, 2025, for a prior felony conviction related to anti-money laundering compliance.

View original document View source feed page

What changed

The Michigan Department of Insurance and Financial Services (DIFS) has issued an order dissolving a previous prohibition order against Changpeng Zhao, the former majority owner of BAM Trading Services Inc. The original order, entered on August 28, 2024, prohibited Zhao from being a licensee or control person of any licensee under the Money Transmission Services Act. This dissolution is a direct result of a full and unconditional presidential pardon granted to Zhao on October 21, 2025, for his November 21, 2023 felony conviction related to failure to maintain an effective Anti-Money Laundering program.

This action effectively removes the prior restriction placed on Changpeng Zhao by DIFS. While the pardon renders the prohibition order moot, DIFS retains jurisdiction over the matter. Regulated entities and individuals previously subject to similar prohibitions should note that pardons can impact the enforceability of prior regulatory actions. No specific compliance actions are required for other entities as this is a specific resolution for an individual based on a presidential pardon.

Source document (simplified)

STATE OF MICHIGAN DEPARTMENT OF INSURANCE AND FINANCIAL SERVICES Before the Director of the Department of Insurance and Financial Services In the matter of: Changpeng Zhao Enforcement Case No. 24-17866 NMLS ID. 1990446 Respondent. ________________________________/ Issued and entered on March 16, 2026 by Aaron Luetzow Senior Deputy Director ORDER DISSOLVING THE AUGUST 28, 2024 PROHIBITION ORDER ENTERED AGAINST CHANGPENG ZHAO Based upon the files and records of the Department of Insurance and Financial Services (DIFS) in this matter, the Senior Deputy Director finds and concludes that: 1. The Senior Deputy Director has jurisdiction and authority to enter this Order Dissolving the August 28, 2024 Prohibition Order entered against Changpeng Zhao pursuant to the Michigan Administrative Procedures Act of 1969 (APA), as amended, MCL 24.201 et seq., and the Money Transmission Services Act (Act), MCL 487.1001 et seq. 2. All required notices have been issued in this case, and the notices and service thereof were received by Respondent or by Respondent’s counsel. 3. All applicable provisions of the Michigan Administrative Procedures Act have been met. 4. Based on its investigation and subsequent litigation of the above-captioned enforcement case, DIFS finds as follows: (a) BAM Trading Services Inc. (License No. MT-0022936) is licensed as a Money Transmission Service Provider under the Act. (b) Changpeng Zhao was majority owner of BAM Trading Services Inc. at all times relevant to the causes of action referenced herein. (c) On or about November 21, 2023, Changpeng Zhao pled guilty to Failure to Maintain an Effective Anti-Money Laundering Program in the United States District Court for the Western District of Washington (Case Number 2:23CR00179RAJ-001). (d) On or about August 28, 2024, DIFS entered an Order Prohibiting Changpeng Zhao from being a licensee, or being employed by, an agent of, or a control person of any

ORDER DISSOLVING PROHIBITION ORDER Enforcement Case No: 24-17866 Page 2 of 2 licensee under the Act or being a licensee or registrant under a financial licensing act, pursuant to Section 47(8) of the Act, MCL 487.1047(8). (e) On or about October 21, 2025, the President of the United States of America granted Changpeng Zhao a full and unconditional presidential pardon from his November 21, 2023 felony conviction. (f) As a result of the October 21, 2025 full and unconditional presidential pardon, the August 28, 2024 Prohibition Order DIFS issued against Changpeng Zhao is now moot. Now therefore, based upon the facts surrounding this case, as set forth above, IT IS ORDERED THAT: 1. The Prohibition Order issued to Changpeng Zhao on August 28, 2024 is DISSOLVED due to his October 21, 2025 full and unconditional presidential pardon. 2. The Senior Deputy Director retains jurisdiction over the matters contained herein and has the authority to issue such further Order(s) as shall be deemed just, necessary, and appropriate in accordance with the Act. _____________________________________ Aaron E. Luetzow Senior Deputy Director