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New Tornado Cash indictments seem to run counter to FinCEN guidance

Roman Storm and Roman Semenov have been indicted for, among other charges, conspiracy to operate an unlicensed money transmitting business. We don't have all the facts but at first blush...

When does a sanction become a seizure? Lessons from the KindHearts case

While researching case law for our Tornado Cash challenge I came across a very interesting holding, KindHearts v. Geithner, that deals with the intersection of the Office of Foreign Assets...

The RESTRICT Act creates blanket authority, with few checks, to ban just about anything linked to a ‘foreign adversary’

The RESTRICT Act, introduced by Senators Warner and Thune, aims to block or disrupt transactions and financial holdings involving foreign adversaries that pose risks to national security. Although the primary...

Tornado Cash is no “golem.” It’s a tool for privacy and free speech.

In a recent article in Lawfare, Henry Farrell and Bruce Schneier defend sanctions imposed on Tornado Cash, a privacy tool on the Ethereum network. They argue that these sanctions are...

Coin Center is suing OFAC over its Tornado Cash sanction

Privacy is not the default on Ethereum. If you do your job on Ethereum, your co-workers can see your salary. If you donate to a political cause on Ethereum, the...

Does the Merge change how Ethereum is regulated? (No.)

The Ethereum Merge is resurfacing questions about regulatory differences between proof-of-stake and and proof-of-work. As we've said many times, we do not believe that the technological differences between POS and...

How does Tornado Cash actually work?

Today Coin Center published a detailed factual explanation of how Tornado Cash works. We worked with several world-class Solidity experts who generously donated their time to look directly at the...

U.S. Treasury sanction of privacy tools places sweeping restrictions on all Americans

Tornado.cash—the website and associated Ethereum addresses—has been added to the OFAC (Office of Foreign Assets Control) SDN list (the list of Specially Designated Nationals with whom Americans and American businesses...

Cryptocurrency isn’t the primary threat to sanctions enforcement

The effect of cryptocurrency technology on the U.S.’s ability to enforce sanctions is a topic that has been receiving more and more government attention. Mostly it has been a reaction...

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