Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 16 AUGUST 2022

OFAC Sanctions A Second Virtual-Currency Mixer

Winston Taylor
Explore more from Winston Taylor

Virtual-currency mixers anonymize cryptocurrency transactions by shuffling them to obfuscate the source and destination of the currency.

GlobalInternational Law
Carl Fornaris
Carl Fornaris
Kimberly A. Prior
Kimberly A. Prior
Cari N. Stinebower
Cari N. Stinebower
Dhruva Krishna
Dhruva Krishna
Dainia J. Jabaji
Dainia J. Jabaji

On August 8, 2022, the U.S. Department of the Treasury's Office of Foreign Assets Control (OFAC) announced its second-ever designation of a virtual-currency mixer—Tornado Cash ("Tornado")—which was used to launder several billion dollars' worth of virtual currency, including funds stolen by a North Korean state-sponsored hacking group.1 Just months ago, OFAC issued its first designation of a virtual-currency mixer—Blender.io—for similar activity.2 As a result of OFAC's designation, all property and interests in property of Tornado and its 50% or more owned subsidiaries are blocked and must be reported to OFAC, and U.S. Persons3 are generally prohibited from directly or indirectly transacting or dealing with them absent a license. This designation (1) reflects the Treasury Department's increased focus and scrutiny on digital-asset companies and related service providers, (2) indicates that mixers should be considered high risk by virtual-currency firms, and (3)

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

See more popular content from

Article

Trump Administration Waives New Russia Sanctions And Tariffs Under Graham Act

President Trump issued an executive order implementing the Graham Act, which establishes substantial new tariffs on Russian goods and countries purchasing Russian energy, but simultaneously waives their application. The order creates a monitoring framework that leaves open the possibility of future enforcement while maintaining existing Russia sanctions regimes.
GlobalInternational Law
Herbert Smith Freehills Kramer LLP
Herbert Smith Freehills Kramer LLP
Article

U.S.-China Trade Truce Extended Two Months: BIS Affiliates Rule Suspension Follows

The U.S.-China trade truce has been extended through January 10, 2027, pushing back the effective date of the Bureau of Industry and Security's Affiliates Rule. While the suspension delays immediate compliance obligations, the rule remains in place and companies should use this additional time to prepare their compliance programs before the suspension potentially expires.
GlobalInternational Law
Crowell & Moring LLP
Crowell & Moring LLP
Article

The Lindsey Graham Sanctions Act: What Businesses Need To Know About The New Tariffs

President Trump signed the Lindsey O. Graham Sanctioning Russia and Iran Act into law on September 18, 2026, establishing mandatory tariffs of up to 500% on Russian goods and up to 100% on goods from countries that continue to buy Russian energy. The Act targets major importers like China, India, and Turkey, with limited relief mechanisms including natural gas exceptions, presidential waivers, and a 270-day winddown period for entities divesting from Russian operations.
GlobalInternational Law
Crowell & Moring LLP
Crowell & Moring LLP
Article

Updates On Export Controls Impacting AI & Advanced Computing

The U.S. Department of Commerce's Bureau of Industry and Security issued guidance on May 31, 2026, clarifying licensing requirements for advanced computing items and AI technologies. The guidance maintains export restrictions for entities in certain countries while providing limited relief for data center operators, though questions remain about future regulatory direction. Companies must now strengthen their compliance programs and supply-chain due diligence as BIS continues to prioritize national security
GlobalInternational Law
Finnegan, Henderson, Farabow, Garrett & Dunner LLP
Finnegan, Henderson, Farabow, Garrett & Dunner LLP