Previously Noah Perlman worked for the cryptocurrency exchange Gemini as the Chief Compliance Officer and then as the Chief Operating Officer. Prior to crypto, Noah had built a compliance-related career spanning decades in leadership positions across big law, United States’ Drug Enforcement Administration (DEA), and banking giant Morgan Stanley.

https://www.binance.com/en/blog/compliance/noah-perlman-building-a-culture-of-compliance-at-binance-5889944569329388319

1. Please introduce your professional background.

Hi, my name is Noel Brahman. I’ve been the Chief Compliance Officer in a finance role for almost two years. Prior to this, I worked at another crypto exchange, Gemini, which was founded by Tyler and Cameron Winklevoss. Before entering the crypto space, I spent nearly 14 years in traditional finance at Morgan Stanley, holding various legal and compliance roles. I actually began my career in government, serving as a federal prosecutor in New York and as counsel to the U.S. Drug Enforcement Administration.

2. What prompted you to enter the crypto industry in 2019? How is compliance management in a crypto company different from traditional industries?

There are actually many similarities. When you think about compliance, especially in the context of blockchain, crypto, and Web3 compared to traditional finance, the core principles remain largely the same. Essentially, it’s about ensuring Know Your Customer (KYC) procedures are in place so that you know who is using your platform. The other primary pillar is, once you have verified users on your platform, making sure you understand their objectives and monitor their transactions.

Of course, there are differences, such as the nature of the underlying assets and the unique aspects of finance in the crypto space, which can vary significantly from traditional finance. Additionally, the global scope and sheer number of users add a layer of operational complexity that brings its own challenges.

3. Why did you choose to join Binance? How did Binance convince you? Weren’t you afraid at that time?

In my opinion, Binance is the most impactful exchange in crypto — it has the most users, the most registrations, and the highest trading volume. The opportunity to work in compliance at this scale was, to be honest, a major career milestone for me. That was a big part of what drew me to join Binance. Before making the decision, I spent considerable time speaking with the founders, including CZ, to ensure they were committed to investing in compliance and building a top-tier program. I also spoke with Richard, the current CEO, to confirm that commitment.

Everyone I spoke with convinced me that Binance was dedicated to establishing best-in-class compliance standards, and two years later, that commitment has absolutely been upheld. We’ve invested hundreds of millions of dollars in our compliance program, significantly expanded our team, and worked diligently to keep up with evolving compliance needs.

4. Binance ultimately reached a favorable settlement with the U.S. Department of Justice. If 100 points is a perfect score, how would you rate the outcome? What were the most critical tasks you handled during the process? What were the key factors for the successful settlement? What advice would you give to other exchanges under investigation?

First and foremost, we’re thrilled to have resolved the issues with U.S. regulators. There were a number of legacy challenges dating back to Binance’s early days. Several years ago, we made a concerted effort to enhance our compliance framework and address these past issues. This commitment was acknowledged last November when we reached a settlement with regulatory agencies, allowing us to close that chapter and focus on the future — a journey we’re very proud of.

The key to achieving this resolution was our genuine commitment to regulatory compliance and the substantial investments we’ve made in this area. We recognize that adherence to a regulatory framework is essential, and we have been actively committed to this for some time.

As for advice to others in the industry, I’d be cautious in offering specific guidance. However, I’ll say that there’s a traditional view in crypto that regulation and crypto are incompatible — that the industry should remain free from regulatory oversight. While I understand that perspective, if we want this industry to grow and attract more users, we must do so responsibly. That’s what Binance is dedicated to, and we encourage others to consider a similar approach. Ultimately, protecting users and fostering responsible growth is essential, especially as governments worldwide have increasingly taken an interest in this space.

5. There were media reports stating that Binance’s compliance team consists of nearly a thousand people. Is this figure accurate? What departments are involved? What are the challenges of managing such a large compliance team?

We like to emphasize that compliance isn’t solely the responsibility of the compliance department — it’s everyone’s responsibility across the entire firm. We have team members fulfilling compliance-related functions throughout the company. Of course, there’s the compliance department that I oversee, but our technology department also plays a key role, with incredibly talented engineers developing compliance solutions that minimize user friction.

Our marketing team is actively involved in shaping compliance messaging, while our content writers focus on educating users about safety and the importance of compliance. Our security team is dedicated to ensuring that the platform remains secure. Compliance truly is a shared responsibility, which creates an exciting environment where everyone is aligned toward the same goals.

Within the compliance department itself, we continue to grow, with the headcount evolving constantly as we make further investments to strengthen the program.

6. What are your views on the regulatory policies in Europe, Dubai, Singapore, and Hong Kong? In your opinion, which region has the best regulatory framework?

I won’t try to pick a “winner” in terms of regulatory environments, but I will say that the frameworks most valued by Binance — and the industry in general — are those that provide clear guidelines. For the industry, having a roadmap or playbook that lays out the rules is essential because it enables us to comply effectively. Clarity also fosters productive dialogue with regulators about potential adjustments. For instance, if there’s a rule about a particular product that the industry believes is safe, we can then engage with regulators, discuss their concerns, and work together toward solutions.

The real challenge arises when there’s a lack of clarity, leaving the industry uncertain about what it can and cannot do. This ambiguity forces companies into a tough position — either to offer a service and risk future criticism or to avoid offering it altogether.

In terms of regulatory regimes and jurisdictions, we value them all and are committed to engaging constructively with each one. From my perspective, in speaking with regulators worldwide, the most helpful regulators are those who approach discussions with an open mind. This doesn’t mean they go easy on us; rather, they’re willing to have a conversation. For instance, if a regulator expresses a concern about user safety, we can then ask what specific issues they’re worried about and address them collaboratively. On the other hand, a regulator who dismisses crypto outright or refuses to consider any dialogue is far less constructive. That said, the regulators you mentioned do not fall into that category — they are open to engagement, which we greatly appreciate.

7. If the Republican Party wins the election, what specific changes do you think will occur in U.S. regulatory policies?

I’m no expert in predicting outcomes, so I won’t speculate on that. Regardless of which party wins the U.S. election, our commitment remains the same: we’re dedicated to working collaboratively with regulatory teams. Although we don’t currently operate in the U.S., it’s a crucial market with significant global influence. So, no matter the election outcome, we’ll continue to engage constructively with regulators, adapting to any changes that come with new leadership.

8. Do you think offshore exchanges will continue to grow in the future, or will the market gradually shift to licensed exchanges?

That’s a good question. I believe it will likely be a balance of both. As regulatory frameworks and licensing systems become more robust and mature, we’ll see a natural gravitation towards these regulated environments. However, offshore activities will still play a role, especially in the near term, as the industry continues to evolve.

9. What are your views on gray areas in regulation? What are the standards for determining whether to fully comply?

That’s a great question. When it comes to gray areas in regulation — whether in traditional finance or crypto — it ultimately boils down to clarity and understanding what regulators truly intend. There are always two approaches: you can either seek permission upfront or move forward and address any issues as they arise. We’re currently focused on gaining clarity first, making sure we fully understand regulatory expectations before taking action.

Of course, clarity isn’t always possible. That said, we operate with 20 licenses globally, making us one of the most regulated exchanges in the industry. This extensive experience has helped us develop a thoughtful approach, even when dealing with ambiguity. Nevertheless, we prefer clear guidance so we can operate responsibly and confidently.

10. How can Binance remain competitive and profitable while being fully compliant?

As Richard often says, we believe compliance is actually a commercial and competitive advantage. The vast majority of users prefer to operate on a platform that is safe and compliant, and this is especially true for institutional players — large firms entering the space want to know they’re working with a compliant platform. When done right, compliance can be a powerful business accelerator, and I believe we’re achieving that.

We’re constantly enhancing our compliance program to minimize friction and prioritize user experience. I’m convinced that it’s the exchanges with strong compliance practices that will ultimately succeed commercially in this space.

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