The three BitMEX co-founders — Arthur Hayes, Benjamin Delo, and Samuel Reed — along with head of business development Gregory Dwyer, each pleaded guilty to a Bank Secrecy Act violation in 2022, received probation sentences and paid millions in criminal and civil penalties, and were then granted full and unconditional presidential pardons by Donald Trump on March 27, 2025.1 The corporate parent, HDR Global Trading Limited, was pardoned the same day.
What the Founders Were Charged With
BitMEX launched in 2014 as a cryptocurrency derivatives platform offering futures, options, and swaps on bitcoin, ether, and litecoin, with leverage of up to 100 to 1. Over its first several years it took in more than $11 billion in bitcoin deposits and earned more than $1 billion in fees. Hayes was CEO, Delo built the trading engine, and Reed served as chief technology officer. Dwyer ran business development.
On October 1, 2020, the U.S. Attorney’s Office for the Southern District of New York unsealed an indictment charging all four with willfully violating the Bank Secrecy Act and conspiring to do so. The case, United States v. Arthur Hayes et al., No. 20-CR-500, went to U.S. District Judge John G. Koeltl.
Prosecutors alleged the founders knew by at least September 2015 that serving U.S. customers required an anti-money laundering program and customer identification procedures, and that they deliberately built neither. Users could trade with only an email address. The indictment said the men incorporated in the Seychelles to dodge U.S. regulation while continuing to solicit American traders, deleted records of U.S.-based customers, and allowed users from sanctioned countries including Iran to access the platform. Hayes was alleged to have boasted that bribing regulators in the Seychelles cost less than complying with U.S. rules.
Reed was the only defendant arrested the day charges were announced. Federal agents took him into custody in Massachusetts on October 1, 2020, and he was released on a $5 million appearance bond secured by $500,000 in cash. Hayes and Delo surrendered between late 2020 and April 2021. Dwyer, living in Bermuda, fought extradition before agreeing to it in September 2021; his case was later severed from the others’.
Guilty Pleas and Sentences
Hayes and Delo pleaded guilty first, on February 24, 2022, each admitting one count of willfully failing to establish and maintain an anti-money laundering program. Each agreed to a $10 million criminal fine. Reed pleaded guilty to the same charge on March 9, 2022, also agreeing to a $10 million fine. Judge Koeltl described Reed as holding a lesser role and being “somewhat less culpable” than Hayes and Delo. Dwyer pleaded guilty on August 8, 2022, with a $150,000 fine in his agreement.
None of the four received prison time. The sentences:
- Arthur Hayes: six months of home detention followed by two years of probation, plus the $10 million fine. Sentenced May 20, 2022.
- Benjamin Delo: thirty months of probation, plus the $10 million fine.
- Samuel Reed: eighteen months of probation, plus the $10 million fine. Sentenced July 13, 2022.
- Gregory Dwyer: twelve months of probation and a $150,000 fine. Sentenced November 16, 2022.
The Civil and Corporate Penalties
The Commodity Futures Trading Commission filed a parallel civil complaint the same day as the indictment, in Case No. 20-cv-8132. It alleged BitMEX operated as an unregistered futures commission merchant, ran an unauthorized swaps trading facility, and violated Bank Secrecy Act customer identification rules.
On August 10, 2021, the court entered a consent order against the five BitMEX corporate entities imposing a $100 million civil penalty, with up to $50 million offset by payments to the Financial Crimes Enforcement Network under a separate settlement and another $20 million suspended pending compliance reviews. FinCEN’s action, announced the same day, found that BitMEX had willfully failed to run an AML program, a customer identification program, or suspicious-activity reporting for more than six years, from November 2014 through December 2020, and that it had conducted at least $209 million in transactions with known darknet markets or unregistered mixing services while failing to file suspicious-activity reports on at least 588 transactions.
On May 5, 2022, the court entered individual consent orders against Hayes, Delo, and Reed, each requiring a $10 million civil monetary penalty. That is separate from the $10 million criminal fine each also paid. All three were permanently enjoined from further Commodity Exchange Act and CFTC violations.
The corporate case wasn’t over either. On July 10, 2024, HDR Global Trading Limited pleaded guilty to one Bank Secrecy Act count. Judge Koeltl sentenced the company on January 15, 2025, to a $100 million criminal fine and two years of probation, rejecting the argument that its earlier civil payments were punishment enough. Combined penalties against BitMEX and its founders exceeded $200 million.
The March 2025 Pardons
On March 27, 2025, President Trump granted full and unconditional pardons to Hayes, Delo, Reed, and Dwyer, clearing their criminal convictions. HDR Global Trading Limited was pardoned as well. The pardons were announced the same day Trump pardoned Nikola founder Trevor Milton.
Delo called the pardon a “vindication,” saying the Justice Department had “wrongfully targeted” the founders and that they had been “sacrificed for political reasons” under an “obscure, antiquated law.” He said the pardon let him continue his life and philanthropic work “without the burden of an unfounded conviction.” Hayes wrote on social media, “Thank you POTUS.”
The pardons cleared the criminal convictions. The research does not indicate that they affected the civil monetary penalties the founders had already paid to the CFTC, and the individual civil consent orders permanently enjoining Hayes, Delo, and Reed from further Commodity Exchange Act violations are not described as disturbed by the clemency grants.
Where BitMEX Stands Now
The exchange kept operating after the settlements and built the compliance infrastructure it had previously refused. BitMEX launched a mandatory user verification program in August 2020 and completed it that December. It appointed a chief compliance officer in October 2020, integrated Chainalysis blockchain-monitoring tools, partnered with surveillance firms for trade monitoring and sanctions screening, and installed an independent director with compliance expertise. By mid-2021, the platform had blocked all U.S. persons and moved its remaining U.S.-based staff out of marketing and solicitation roles.