Where it came from
The CFTC's 2020 complaint states that HDR Global Trading Limited "was incorporated in the Seychelles in 2014 as a Seychelles International Business Company" and that it has owned and operated the BitMEX trading platform since. The Justice Department dates the founding the same way and names Arthur Hayes, Benjamin Delo and Samuel Reed as the founders, with Gregory Dwyer joining in 2015 as the first employee.
BitMEX is a derivatives venue rather than a place to buy coins. Its contracts are margined and settled in bitcoin, which is the detail that matters here: a trader posts bitcoin, takes a position sized many times that stake, and is paid or liquidated in bitcoin. The perpetual swap, a futures contract with no expiry held to the spot price by a periodic funding payment between longs and shorts, was popularised by BitMEX and is now standard across the industry. The CFTC order records leverage of up to 100 to 1 and deposits of more than $11 billion in bitcoin over the platform's first six years.
The company later added spot trading and a token, and it now verifies every user, which it did not do at all for its first six years.
On the record
This is a compliance case, not a fraud case, and no court or regulator has found otherwise.
On 10 August 2021 the United States District Court for the Southern District of New York entered a consent order requiring five BitMEX entities to pay a $100 million civil penalty for operating an unregistered trading facility and for failing to implement customer identification and anti-money-laundering programmes, with up to $50 million offset against a parallel FinCEN assessment.
On 10 July 2024 HDR Global Trading Limited pleaded guilty to violating the Bank Secrecy Act by wilfully failing to establish and maintain an adequate anti-money-laundering and know-your-customer programme. On 15 January 2025 the same court sentenced the company to a $100 million fine and two years' probation. Hayes, Delo, Reed and Dwyer had each pleaded guilty to the same statute and were sentenced in 2022 to probation and fines.
The Office of the Pardon Attorney records that on 27 March 2025 all four men and HDR Global Trading Limited received full pardons.