$500K civil penalty on top of a $297M criminal guilty plea — the CFTC waived disgorgement entirely because DOJ already extracted the real money. This consent order is about establishing a permanent registration bar, full stop. Meanwhile $110-184M in US trading fees flowed through KuCoin while Americans were "blocked" — every offshore CEX running VPN-permissive KYC just watched what happens when the CFTC comes back for seconds after DOJ is done with you.

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