The claims can be summarized as follows:

(Introduction: In the USA, it works in such a way that when a US citizen deposits money, these funds must be processed by organizations that have licenses in the USA, and these funds should be protected, ensuring that citizens have guarantees to withdraw their profits and their investments at any time.)

1. Binance unlawfully encouraged people from the USA to trade on platforms other than Binance.us, while they were legally required to trade exclusively on Binance.us.
2. Binance engaged in numerous unregistered trading activities, including offering services like buying, selling, conversions, futures trading, and loans without obtaining the necessary licenses from the US government, which is a violation of the law.
3. Binance performed functions of an exchange, broker, and clearinghouse, carrying out activities like accepting funds and processing transactions, all without the appropriate licenses. Furthermore, they deliberately structured these functions to evade regulatory oversight.
4. The US SEC has specific concerns related to Binance's tokens, including "BNB," "BUSD," "BNB Vault," "Simple Earn," and "staking."
5. Binance raised billions from investors for its management company BAM through Binance.com, exceeding the officially declared fundraising limit of 200 million.
6. Binance employed various complex methods to enable US users to trade on Binance.com, effectively evading US regulatory requirements.
7. Binance was allegedly involved in transferring client funds to another company, "Merit Peak Limited," which could potentially be used for purchasing assets, trading cryptocurrencies, and inflating certain assets, although this aspect remains theoretical and unproven.
8. Binance allegedly engaged in "wash trading" through its intermediary companies "BAM Trading" and "BAM Management" using client funds. "Wash trading" refers to the practice of artificially inflating trading volumes, essentially manipulating the price of cryptocurrencies to attract retail traders. An example in the case provided is the company "Sigma Chain," whose owner was CZ. It was heavily involved in "wash trading" on Binance.us from September 2019 to June 2022.
9. Binance conducted unlawful ICOs, IDOs, and similar offerings, all without protecting investors' investments and lacking the necessary regulations required in the USA. Additionally, they failed to disclose information about the owners and issuers to the SEC and Congress, employing complex systems to obfuscate these details.
10. The SEC requests that on Binance.us, neither CZ nor companies like binance.com should have any influence indefinitely, as they have violated numerous regulations. This request raises the possibility of legal actions against CZ. While the SEC might seek to close down binance.com and potentially take action against CZ, it is likely that they will not pursue the case as aggressively as with founders of some other platforms, as Binance may not have defrauded as much money from US investors as others, which is why the SEC, rather than the FBI, is handling this case.

Binance.com created a network of products that are under the control of affiliated organizations in various jurisdictions, all of which are linked to CZ as the beneficial owner. This suggests that CZ effectively takes ownership of everything.

BAM Management is a Delaware corporation and the parent company of BAM Trading and other affiliated companies. CZ owns 85% of this company. Many products targeting the US market are owned by this corporation.

There's an extensive network of companies affiliated with CZ (a Canadian citizen) implicated in various questionable activities, which is illustrated in the attached diagram.

Facts: CZ initiated a financial startup named Binance, which raised funds for the startup by selling the "BNB" token at $0.15 each, earning $15 million. This is akin to considering Binance's BNB token as a stock.

As of 2021, Binance had a trading volume of $9.58 trillion, making it the world's largest trading platform.

Between July 18 and July 21, 2021, Binance earned at least $11.6 billion, a substantial amount comparable to Nvidia's earnings in the previous year.

Binance.com regularly attempted to attract US customers, but Binance was not actively enforcing Know Your Customer (KYC) procedures.