Case 1:23-cv-01599 Document 4 Filed 06/06/23 Page 1 of 4

UNITED STATES DISTRICT COURTFOR THE DISTRICT OF COLUMBIA__________________________________________
SECURITIES AND EXCHANGE)COMMISSION,))
Plaintiff,))v.
)
Civil Action No. 1:23-cv-01599)
BINANCE HOLDINGS LIMITED,)BAM TRADING SERVICES INC.,)
BAM MANAGEMENT US HOLDINGS)
INC., AND CHANGPENG ZHAO,))
Defendants.
)__________________________________________)PLAINTIFF U.S. SECURITIES AND EXCHANGE COMMISSION’SEMERGENCY MOTION FOR A TEMPORARY RESTRAINING ORDER
FREEZING ASSETS, GRANTING OTHER RELIEF, AND
ORDER TO SHOW CAUSE WHY RELIEF SHOULD NOT CONTINUE
Pursuant to Section 21(d) of the Securities Exchange Act of 1934 (“Exchange Act”) [15U.S.C. § 78u(d)] and Section 20(b) of the Securities Act of 1933 (“Securities Act”) [15 U.S.C.
§§ 77t(b)], Plaintiff U.S. Securities and Exchange Commission (“SEC”) requests that this Court
issue a temporary restraining order:(i)freezing assets (both known and unknown) of Defendant BAM Management US
Holdings Inc. (“BAM Management”) and BAM Trading Services Inc. (“BAMTrading”) (collectively, “BAM”), as set forth in the supporting Memorandum ofLaw and proposed restraining order and specifically including those in Exhibit A
to the Motion and Proposed Order;(ii)

ordering the repatriation and other specified relief concerning the custody andcontrol of fiat currency and crypto assets deposited, held, traded, and/or accruedby customers on the Binance.US crypto asset trading platform (“Binance.USCase 1:23-cv-01599 Document 4 Filed 06/06/23 Page 2 of 4Platform”) or otherwise held for the benefit of customers of BAM and theBinance.US Platform (collectively, “Customer Assets”);(iii)

directing Defendants Binance Holdings Limited (“Binance”), BAM Trading,BAM Management, and Changpeng Zhao (“Zhao”) to show cause why apreliminary injunction should not be entered;(iv)

prohibiting Defendants from destroying, altering, or concealing relevant records;(v)

requiring sworn accountings from Defendants;(vi)ordering expedited discovery;(vii)

authorizing alternative means of service; and(viii) ordering any other equitable relief necessary to protect investors and effectuate
the requested relief.
The SEC respectfully submits that this relief is necessary on an expedited basis to ensure
the safety of customer assets and prevent the dissipation of available assets for any judgment,
given the Defendants’ years of violative conduct, disregard of the laws of the United States,
evasion of regulatory oversight, and open questions about various financial transfers and thecustody and control of Customer Assets—including by Defendants who claim they are notsubject to the Court’s jurisdiction—as described in the Complaint, Memorandum of Law, andsupporting materials
In support of this Motion, the SEC relies upon and incorporates by reference theComplaint, the supporting Memorandum of Law, the Declarations of Sachin Verma and Colby
Steele of the SEC and their respective attachments, and the Certification Pursuant to Federal
Rule of Civil Procedure 65 and Local Rule 65.1 (“Certification”).

2Case 1:23-cv-01599 Document 4 Filed 06/06/23 Page 3 of 4Pursuant to Federal Rule of Civil Procedure 65 and Local Rule 65.1, undersigned counsel
for the SEC has certified in the attached Certification that, contemporaneously with the filing ofthe Motion for a Temporary Restraining Order and accompanying materials, the SEC has
provided copies of all pleadings and papers filed in this action to date or to be presented to theCourt at the hearing, including the Motion for a Temporary Restraining Order.
For all the reasons set forth in the supporting Memorandum of Law, the Complaint, andthe other documents referenced above, the SEC respectfully requests that the Court grant theSEC’s Motion and issue an order providing all of the relief requested herein. For the Court’s
convenience, the SEC has also contemporaneously filed a proposed order.

Dated: June 6, 2023
Washington, D.C.

By:____/s/___Matthew Scarlato__________________
Matthew Scarlato (D.C. Bar No. 484124)
Jennifer L. Farer (D.C. Bar No. 1013915)
J. Emmett Murphy*
U.S. SECURITIES AND EXCHANGE
COMMISSION
100 F Street N.E.
Washington, D.C. 20549
Phone:(202) 551-3746 (Scarlato)(202) 551-5072 (Farer)(212) 336-0078 (Murphy)
Emails:scarlatom@sec.gov
farerj@sec.gov
murphyJoh@sec.gov
Attorneys for the Plaintiff*Government attorney certification pursuant toLocal Rule 83.2(d) pending

Of Counsel:

Jorge G. Tenreiro
David L. HirschDavid A. Nasse
Michael Baker
Kathleen Hitchens3Case 1:23-cv-01599 Document 4 Filed 06/06/23 Page 4 of 4

Donna Norman
Ann Rosenfield
Colby Steele
Martin Zerwitz
SECURITIES AND EXCHANGE
COMMISSION4