BIT Mining, Ltd. was a cryptocurrency mining company incorporated in the Cayman Islands and headquartered in Hong Kong. Prior to 2019, the company operated under the name 500.com Ltd. and was a Chinese online sports lottery company also incorporated in the Cayman Islands but with its principal office in Shenzhen, China. 500.com's securities traded on the New York Stock Exchange and the NASDAQ under the ticker symbol WBAI. Effective April 20, 2021, 500.com changed its NYSE ticker symbol from WBAI to BTCM.
500.com Nihon Co. Ltd. was a wholly owned subsidiary of 500.com, headquartered in Tokyo, Japan. The subsidiary's books, records, and accounts were consolidated into the financial statements 500.com filed with the SEC.
According to court documents, between 2017 and 2019, 500.com's then-CEO -- Zhengming Pan, who was also a director of 500.com Nihon -- conspired with employees and third-party consultants to pay approximately $1.9 million in bribes to Japanese government officials, including a member of the country's national legislature. 500.com was attempting to win a bid to open an integrated resort (a large resort that includes hotels, casinos, retail, dining, convention facilities, and entertainment venues) in Japan. The bribes took the form of cash, travel, entertainment, and gifts, and Pan allegedly covered up the bribes by, among other things, entering into sham contracts with the consultants and falsely recording the payments as legitimate expenses, including as management advisory fees. Ultimately, however, 500.com did not win an integrated resort bid in Japan.
On November 18, 2024, the DOJ filed a two count information in the District of New Jersey against BIT Mining alleging a conspiracy to violate the anti-bribery and books and records provisions of the FCPA as well as direct violations of the books and records provisions of the FCPA. On the same date, the company entered into a deferred prosecution agreement with the DOJ. Under the terms of the settlement, BIT Mining agreed to pay a criminal fine of $10 million, which was reduced from $54 million due to the company's inability to pay, and to report to the DOJ on the status of the company's anticorruption compliance for a term of three years. The $54 million fine represented a 10 percent reduction off the bottom of the sentencing guidelines range. The DOJ agreed to credit up to $4 million against the penalty for money paid to the SEC in its parallel proceeding. The DOJ noted the company's cooperation and remediation.
