Binance has maneuvered through dozens of regulatory ecosystems to become the world’s largest cryptocurrency exchange with a daily trading volume exceeding that of its next four competitors combined. But even as its CEO Changpeng Zhao recently became the richest Asian man, the company’s presence in Asia — where Binance got its start — is shrinking. 

The company’s headquarters also remains shrouded in mystery.

Binance is currently winding down its digital token payments business in Singapore after it became clear that regulators would not approve its application for a crypto license, and all customer accounts on will close on Feb. 13, according to the company.

The crypto exchange is also currently banned or battling regulatory challenges in Hong Kong, Japan, Malaysia and Australia, not to mention Italy, the U.K. and the U.S. Binance left China, where it was founded, in 2017 before a wave of government crackdowns there on crypto companies.

Pakistan recently became the latest country to launch an investigation against Binance in connection with an alleged US$100 million fraud perpetrated by Binance-integrated apps.

Binance operates in countries through roughly 50 entities, but it is not publicly known where in the world its corporate parent or headquarters is registered. Last year, it was reported that Binance was registered in the Cayman Islands — but the island nation then forcefully dispelled that rumor, saying that it had no regulatory authority over the crypto exchange.

When contacted by Forkast, a Binance spokesperson said: “We do not comment on specific matters with regulatory and law enforcement authorities. However, as a matter of policy our general approach is to cooperate with investigations wherever possible.” Binance did not respond to questions from Forkast regarding its corporate headquarters.

In a video interview, CEO Zhao told Forkast that “for, we are actually not based anywhere.” He also spoke of not having a defined headquarters as a point of pride — something akin to decentralization.

But the increasing regulatory heat has prompted a change of heart at Binance over matters involving corporate headquarters.

Binance is now hoping to set up its new headquarters in the United Arab Emirates and has held talks with officials in the cities of Abu Dhabi and Dubai, where CEO Zhao recently bought a new home, according to Bloomberg.

The opacity in Binance’s corporate structure has been vexing regulators and customers alike, especially those trying to seek accountability or legal recourse when problems occur. A corporation operating without any headquarters is also something that crypto legal experts say they have a hard time believing.

“Realistically, Binance is incorporated somewhere and there are specific companies that are responsible for specific things that could be held accountable when issues arise. But the issue is, it’s impossible to find out,” Aija Lejniece, a crypto lawyer based in Paris, told Forkast

Binance’s terms and conditions significantly limit not only Binance’s liabilities but what legal recourse users can seek, although the legal validity of these clauses is not clear. 

For instance, Binance’s terms say that the company is not liable for any damages arising from Binance’s services or its failure thereof. Additionally, the terms dictate that for disputes, users may not litigate in courts in their home country but must resort to international arbitration, which can be prohibitively expensive. The median cost of arbitration at the Hong Kong International Arbitration Center, for instance, is close to US$65,000. 

“So unless you have lost a lot of money and still have money, most people are not positioned” to pursue any legal recourse against Binance, Lejniece said. 

Hiding behind a veil of corporate entities can help a company save on taxes if the registration is in a tax-friendly jurisdiction. It also can help a company avoid the burden and cost of regulatory compliance of being licensed in stricter jurisdictions.

As crypto regulators intensify their scrutiny over companies like Binance, will Binance’s corporate structures become more transparent? So far, the crackdowns may be resulting in fewer places for Binance to operate — or hide.