{"investigation":{"slug":"tornado-cash","entity_name":"Tornado Cash","trust_score":28,"severity_base":null,"score_modifier":-12,"confidence":0.85,"status":"draft","content_type":"investigation","summary":"Tornado Cash is an open-source, non-custodial cryptocurrency mixing protocol on Ethereum, launched in 2019, that obscures the on-chain link between deposit and withdrawal addresses. The U.S. Treasury sanctioned the protocol in August 2022 over its alleged use by the North Korea-linked Lazarus Group and other illicit actors to launder billions of dollars; those sanctions were struck down by the Fifth Circuit in November 2024 and formally lifted by OFAC in March 2025. Separately, co-founder Alexey Pertsev was convicted of money laundering in the Netherlands in 2024 (appeal pending), and co-founder Roman Storm was convicted in August 2025 of one count of conspiring to operate an unlicensed money-transmitting business while a New York jury deadlocked on more serious money-laundering and sanctions-violation charges that remain unresolved pending post-trial motions and a possible retrial.","sections":[{"content":"Tornado Cash is a decentralized, non-custodial privacy protocol built on the Ethereum blockchain that allows users to deposit cryptocurrency and later withdraw it to a different address, breaking the on-chain link between the source and destination of funds. It operates through immutable smart contracts and does not require the operator to take custody of user funds. According to the U.S. Treasury, Tornado Cash was created in 2019 and had been used to launder more than $7 billion worth of virtual currency since its creation, as of the August 2022 sanctions designation. The protocol has been described by supporters as a legitimate financial-privacy tool and by U.S. regulators as a vehicle repeatedly exploited by cybercriminals and a state-sponsored hacking group.","heading":"Protocol Overview","sources":[{"url":"https://home.treasury.gov/news/press-releases/jy0916","name":"U.S. Treasury press release, jy0916 (Aug. 8, 2022 designation)","type":"regulatory","credibility":1},{"url":"https://en.wikipedia.org/wiki/Tornado_Cash","name":"Tornado Cash — Wikipedia","type":"other","credibility":2},{"url":"https://www.chainalysis.com/blog/tornado-cash-ofac-designation-sanctions/","name":"Chainalysis: The Tornado Cash Sanctions","type":"research","credibility":2}],"severity":"high"},{"content":"Tornado Cash was created by Roman Storm, Roman Semenov, and Alexey Pertsev, with the initial version released in 2019. Roman Storm is a U.S. resident who lived in Auburn, Washington; Roman Semenov is a Russian national who, according to reporting, has been based in Dubai and remains outside U.S. jurisdiction; Alexey Pertsev is a Russian national who was resident in the Netherlands. All three have faced legal action tied to their roles in developing and promoting the protocol: Pertsev was prosecuted and convicted in the Netherlands, Storm was prosecuted and partially convicted in the United States, and Semenov was criminally charged in the U.S. and separately designated by OFAC, but as a non-resident has not been arrested or tried.","heading":"Founders and Key Individuals","sources":[{"url":"https://www.fbi.gov/news/stories/tornado-cash-co-founders-accused-of-helping-cybercriminals-launder-stolen-crypto","name":"FBI: Tornado Cash Co-Founders Accused of Helping Cybercriminals Launder Stolen Crypto","type":"official","credibility":1},{"url":"https://therecord.media/us-arrests-tornado-cash-cofounder","name":"The Record: US arrests Tornado Cash co-founder, sanctions another who remains at large","type":"news_article","credibility":2},{"url":"https://home.treasury.gov/news/press-releases/jy1702","name":"U.S. Treasury: Treasury Designates Roman Semenov, Co-Founder of Sanctioned Virtual Currency Mixer Tornado Cash (jy1702)","type":"regulatory","credibility":1}],"severity":"high"},{"content":"On August 8, 2022, the U.S. Treasury's Office of Foreign Assets Control (OFAC) designated Tornado Cash under Executive Order 13694, adding the protocol and a large number of associated Ethereum addresses to the Specially Designated Nationals and Blocked Persons (SDN) List. Treasury stated that Tornado Cash \"has been used to launder more than $7 billion worth of virtual currency since its creation in 2019,\" and that it was used by the North Korea-linked Lazarus Group to launder over $455 million stolen in what Treasury called \"the largest known virtual currency heist to date.\" Treasury also alleged Tornado Cash was used to launder more than $96 million connected to the June 24, 2022 Harmony Bridge exploit and at least $7.8 million from the August 2, 2022 Nomad Heist. The designation was novel in sanctioning an open-source software protocol and its associated smart-contract addresses rather than a specific person or corporate entity, a feature that became central to subsequent litigation.","heading":"OFAC Sanctions — August 2022","sources":[{"url":"https://home.treasury.gov/news/press-releases/jy0916","name":"U.S. Treasury press release, jy0916","type":"regulatory","credibility":1},{"url":"https://ofac.treasury.gov/recent-actions/20220808","name":"OFAC Recent Action, August 8, 2022","type":"regulatory","credibility":1},{"url":"https://www.chainalysis.com/blog/tornado-cash-ofac-designation-sanctions/","name":"Chainalysis: The Tornado Cash Sanctions","type":"research","credibility":2}],"severity":"critical"},{"content":"A group of Tornado Cash users, led by plaintiff Joseph Van Loon, sued the Treasury Department arguing that OFAC exceeded its statutory authority under the International Emergency Economic Powers Act (IEEPA) because immutable smart contracts are not \"property\" capable of being owned or blocked, and because Tornado Cash lacks the legal personhood required to be a sanctionable \"entity.\" On August 17, 2023, the U.S. District Court for the Western District of Texas ruled for the government, with Judge Robert Pitman granting summary judgment upholding the sanctions and rejecting the plaintiffs' First Amendment and IEEPA arguments. The plaintiffs appealed, and on November 26, 2024, the U.S. Court of Appeals for the Fifth Circuit reversed, holding that Tornado Cash's immutable smart contracts are not \"property\" under IEEPA because they cannot be owned, controlled, or altered by anyone, including their creators, and remanding with instructions to grant partial summary judgment to the plaintiffs under the Administrative Procedure Act.","heading":"Van Loon Civil Challenge — Texas District Court and Fifth Circuit","sources":[{"url":"https://www.ca5.uscourts.gov/opinions/pub/23/23-50669-CV0.pdf","name":"Van Loon v. Department of the Treasury, No. 23-50669 (5th Cir. Nov. 26, 2024)","type":"court_filing","credibility":1},{"url":"https://decrypt.co/153118/tornado-cash-sanctions-affirmed-by-federal-court","name":"Decrypt: Tornado Cash Sanctions Affirmed by Federal Court","type":"news_article","credibility":2},{"url":"https://www.jonesday.com/en/insights/2024/12/fifth-circuit-reverses-tornado-cash-sanctions-ruling","name":"Jones Day: Immutable Code Is Not Property: Fifth Circuit Reverses Tornado Cash Sanctions Ruling","type":"research","credibility":2}],"severity":"high"},{"content":"Following the Fifth Circuit's ruling, the U.S. Treasury's OFAC announced on March 21, 2025 that it was removing Tornado Cash — including its front-end website and associated smart-contract addresses — from the SDN List, ending roughly two and a half years of sanctions. Treasury framed the move as a discretionary policy decision rather than a concession, stating it had \"exercised [its] discretion to remove the economic sanctions against Tornado Cash\" based on review of \"the novel legal and policy issues raised by use of financial sanctions against financial and commercial activity occurring within evolving technology and legal environments.\" The delisting did not extend to co-founder Roman Semenov, who remains individually sanctioned, and Treasury's statement reiterated continuing concern about North Korean state-sponsored cyber theft and money laundering. Plaintiffs' counsel in the Van Loon litigation have characterized the delisting as an attempt to moot the case while preserving the government's ability to re-designate the protocol in the future.","heading":"OFAC Delisting — March 2025","sources":[{"url":"https://home.treasury.gov/news/press-releases/sb0057","name":"U.S. Treasury: Tornado Cash Delisting (sb0057)","type":"regulatory","credibility":1},{"url":"https://ofac.treasury.gov/recent-actions/20250321","name":"OFAC Recent Action, March 21, 2025","type":"regulatory","credibility":1},{"url":"https://www.coindesk.com/policy/2025/03/21/u-s-government-removes-tornado-cash-sanctions","name":"CoinDesk: U.S. Government Removes Tornado Cash Sanctions","type":"news_article","credibility":2},{"url":"https://www.mondaq.com/unitedstates/fin-tech/1604006/treasury-department-delists-tornado-cash-following-the-fifth-circuits-decision","name":"Mondaq/Steptoe: Treasury Department Delists Tornado Cash Following the Fifth Circuit's Decision","type":"research","credibility":2}],"severity":"medium"},{"content":"Alexey Pertsev was arrested in the Netherlands in August 2022 on suspicion of money laundering. On May 14, 2024, the District Court of Oost-Brabant (sitting in 's-Hertogenbosch) found him guilty of money laundering and sentenced him to 64 months (five years and four months) in prison. The court found that Tornado Cash had been used to launder more than $1.2 billion in illicit crypto assets between July 2019 and Pertsev's 2022 arrest, and held that Pertsev and his co-founders were responsible for failing to build in mechanisms to prevent the platform's misuse despite the foreseeability of criminal use. Pertsev appealed the conviction. On February 7, 2025, a Dutch court suspended his pretrial detention pending appeal, releasing him under electronic monitoring conditions that he described as falling short of \"real freedom.\" Reporting as of April 2026 indicates the Court of Appeal of 's-Hertogenbosch ordered him to continue to be detained pending the appeal, meaning the underlying conviction has not been finally resolved and remains under appellate review.","heading":"Alexey Pertsev — Netherlands Criminal Proceedings","sources":[{"url":"https://www.coindesk.com/policy/2024/05/14/tornado-cash-developer-alexey-pertsev-found-guilty-of-money-laundering","name":"CoinDesk: Tornado Cash Developer Alexey Pertsev Found Guilty, Sentenced to 64 Months in Prison by Dutch Court","type":"news_article","credibility":2},{"url":"https://www.axios.com/2024/05/14/tornado-cash-alexey-pertsev-crypto","name":"Axios: Tornado Cash developer Alexey Pertsev convicted","type":"news_article","credibility":1},{"url":"https://thehackernews.com/2024/05/dutch-court-sentences-tornado-cash-co.html","name":"The Hacker News: Dutch Court Sentences Tornado Cash Co-Founder","type":"news_article","credibility":2},{"url":"https://decrypt.co/304723/tornado-cash-developer-alexey-perstev-leaving-prison","name":"Decrypt: Tornado Cash Developer Alexey Pertsev Leaving Prison on Supervised Release","type":"news_article","credibility":2},{"url":"https://dailyhodl.com/2025/02/07/tornado-cash-developer-alexey-pertsev-released-from-dutch-prison-as-he-appeals-five-year-sentence/","name":"The Daily Hodl: Tornado Cash Developer Alexey Pertsev Released From Dutch Prison As He Appeals Five-Year Sentence","type":"news_article","credibility":2}],"severity":"critical"},{"content":"On August 23, 2023, the U.S. Department of Justice unsealed an indictment in the Southern District of New York charging Roman Storm and Roman Semenov with conspiracy to commit money laundering, conspiracy to violate U.S. sanctions, and conspiracy to operate an unlicensed money-transmitting business, alleging the pair facilitated more than $1 billion in money laundering through Tornado Cash, including for the Lazarus Group. Storm was arrested the same day at his home in Washington state and released on bail days later; Semenov, outside U.S. jurisdiction, was simultaneously designated by OFAC. Storm's case proceeded to trial in the Southern District of New York before Judge Katherine Polk Failla. On August 6, 2025, a jury found Storm guilty of conspiracy to operate an unlicensed money-transmitting business, which carries a statutory maximum of five years, but deadlocked on the two more serious charges — conspiracy to commit money laundering and conspiracy to violate sanctions, each carrying up to 20 years — resulting in a partial mistrial on those counts. Storm remained free on bail. He subsequently filed a Rule 29 motion for acquittal on the surviving count, with oral argument held April 9, 2026; as of this writing the court had not yet ruled. Reporting from March 2026 indicated prosecutors sought an October 2026 retrial date on the deadlocked counts, but later reporting (August 2026) indicates the retrial has been pushed back to April 26, 2027, pending resolution of Storm's acquittal motion, with a final pretrial conference set for April 20, 2027. Storm has not yet been sentenced on his conviction.","heading":"Roman Storm — U.S. Criminal Prosecution","sources":[{"url":"https://www.justice.gov/archives/opa/pr/tornado-cash-founders-charged-money-laundering-and-sanctions-violations","name":"DOJ (Archives): Tornado Cash Founders Charged with Money Laundering and Sanctions Violations","type":"official","credibility":1},{"url":"https://www.irs.gov/pub/irs-ci/j5-media-release-8-29-2023.pdf","name":"IRS-CI press release, Aug. 29, 2023 (J5 media release)","type":"official","credibility":1},{"url":"https://edition.cnn.com/2023/08/23/business/tornado-cash-crypto-roman-storm/index.html","name":"CNN: Tornado Cash cryptocurrency co-founders Roman Storm and Semonov indicted for laundering for Lazarus Group","type":"news_article","credibility":1},{"url":"https://www.moneylaunderingnews.com/2025/08/tornado-cash-jury-deadlocked-on-most-serious-charges-but-convicted-founder-roman-storm-on-conspiracy-to-operate-an-unlicensed-money-transmitting-business/","name":"Money Laundering Watch: Tornado Cash Jury Deadlocked on Most Serious Charges, but Convicted Founder Roman Storm on Conspiracy to Operate an Unlicensed Money Transmitting Business","type":"news_article","credibility":2},{"url":"https://www.irs.gov/compliance/criminal-investigation/founder-of-tornado-cash-crypto-mixing-service-convicted-of-knowingly-transmitting-criminal-proceeds","name":"IRS-CI: Founder of Tornado Cash crypto mixing service convicted of knowingly transmitting criminal proceeds","type":"official","credibility":1},{"url":"https://bitcoinmagazine.com/news/tornado-cash-trial-concludes-roman-storm-found-guilty-of-one-of-three-counts","name":"Bitcoin Magazine: Tornado Cash Trial Concludes, Roman Storm Found Guilty of One of Three Counts","type":"news_article","credibility":2},{"url":"https://www.coindesk.com/policy/2025/08/06/roman-storm-jury-deadlocked-judge-tells-them-to-keep-deliberating","name":"CoinDesk: Roman Storm Jury Deadlocked, Judge Tells Them to Keep Deliberating","type":"news_article","credibility":2},{"url":"https://www.theblock.co/news/regulation/2026-08-26-tornado-cash-roman-storm-retrial-april-2027-412761","name":"The Block: Tornado Cash developer Roman Storm's retrial pushed back to April 2027","type":"news_article","credibility":2},{"url":"https://www.theblock.co/post/392937/roman-storm-tornado-cash-retrial","name":"The Block: US prosecutors seek October 2026 retrial for Tornado Cash co-founder Roman Storm","type":"news_article","credibility":2},{"url":"https://thedefiant.io/news/regulation/tornado-cash-developer-roman-storm-awaits-judge-s-ruling-on-acquittal-bid","name":"The Defiant: Tornado Cash Developer Roman Storm Awaits Judge's Ruling on Acquittal Bid","type":"news_article","credibility":2}],"severity":"critical"},{"content":"The Van Loon litigation and the broader Tornado Cash sanctions episode generated substantial legal-policy commentary. Critics, including the nonprofit Coin Center, argued OFAC exceeded its authority by treating immutable, ownerless smart-contract code as a sanctionable \"entity\" or \"property,\" noting that unlike a company such as Blender.io, the Tornado Cash protocol has no legal personhood, cannot be sued, cannot own property, and cannot itself contest a designation. Plaintiffs in Van Loon also raised First Amendment arguments regarding the right to engage in private financial transactions and \"socially valuable speech,\" which the district court rejected in 2023; the Fifth Circuit's 2024 ruling was decided on statutory (IEEPA/APA) rather than constitutional grounds. The case has been cited as an early post-Loper Bright example of appellate courts declining to defer to agency interpretations of sanctions statutes in the crypto context.","heading":"Constitutional and Policy Debate","sources":[{"url":"https://coincenter.org/analysis-what-is-and-what-is-not-a-sanctionable-entity-in-the-tornado-cash-case/","name":"Coin Center: Analysis — What is and what is not a sanctionable entity in the Tornado Cash case","type":"research","credibility":2},{"url":"https://www.velaw.com/insights/citing-loper-fifth-circuit-declines-agency-deference-overturns-sanctions-against-cryptocurrency-software/","name":"V&E: Citing Loper, Fifth Circuit Declines Agency Deference, Overturns Sanctions Against Cryptocurrency Software","type":"research","credibility":2},{"url":"https://www.yalejreg.com/nc/van-loon-v-department-of-the-treasury-a-decision-with-important-implications-for-bitcoin-by-steven-a-levy/","name":"Yale Journal on Regulation: Van Loon v. Department of the Treasury – A Decision with Important Implications","type":"research","credibility":2}],"severity":"medium"},{"content":"U.S. authorities and blockchain analytics firms have repeatedly documented alleged use of Tornado Cash by the North Korea-linked Lazarus Group to launder proceeds of major crypto thefts, most notably the roughly $455–620 million (depending on valuation date) Ronin/Axie Infinity bridge hack that Treasury cited as underpinning the 2022 sanctions. TRM Labs and Chainalysis have published on-chain analysis tracing Lazarus-linked funds moving through the protocol both before and after the 2022 designation. Following the March 2025 delisting, commentary from firms including Chainalysis has noted the removal of sanctions restored legal access to the protocol for U.S. persons but did not eliminate its attractiveness to illicit actors, and Treasury's own delisting statement stated the government remains \"deeply concerned about the significant state-sponsored hacking and money laundering campaign\" attributed to North Korea. Individual co-founder Roman Semenov remains separately designated by OFAC notwithstanding the protocol-level delisting.","heading":"North Korea / Lazarus Group Nexus","sources":[{"url":"https://www.trmlabs.com/resources/blog/north-koreas-lazarus-group-moves-funds-through-tornado-cash","name":"TRM Labs: North Korea's Lazarus Group Moves Funds Through Tornado Cash","type":"research","credibility":2},{"url":"https://www.chainalysis.com/blog/tornado-cash-sanctions-challenges/","name":"Chainalysis: Tornado Cash Sanctions Challenges","type":"research","credibility":2},{"url":"https://home.treasury.gov/news/press-releases/sb0057","name":"U.S. Treasury: Tornado Cash Delisting (sb0057)","type":"regulatory","credibility":1}],"severity":"high"},{"content":"Legal commentators have framed Roman Storm's partial conviction as a significant, unresolved test of software-developer liability for privacy-preserving financial tools. Analysis from Mayer Brown noted the verdict signals that developers of decentralized platforms may face licensing obligations as money-transmitting businesses even absent direct control over user funds, and that claiming a tool is a \"neutral\" piece of software may not by itself preclude criminal exposure where a jury finds the developer had knowledge of illicit use and failed to implement safeguards. At the same time, the jury's deadlock on the money-laundering and sanctions conspiracy counts — which required proof of intent to further specific unlawful conduct — has been cited by defense-aligned commentators, including the DeFi Education Fund, as evidence that prosecutors could not establish the more direct culpability theories, leaving significant legal uncertainty for open-source developers pending the resolution of Storm's post-trial motions and any retrial.","heading":"Implications for Developer Liability","sources":[{"url":"https://www.mayerbrown.com/en/insights/publications/2025/08/the-tornado-cash-trials-mixed-verdict-implications-for-developer-liability","name":"Mayer Brown: The Tornado Cash Trial's Mixed Verdict — Implications for Developer Liability","type":"research","credibility":2},{"url":"https://www.defieducationfund.org/us-v-storm-background-timeline/","name":"DeFi Education Fund: U.S. v. Storm — Background and Timeline","type":"research","credibility":2},{"url":"https://coincenter.org/analysis-what-is-and-what-is-not-a-sanctionable-entity-in-the-tornado-cash-case/","name":"Coin Center: Analysis — What is and what is not a sanctionable entity in the Tornado Cash case","type":"research","credibility":2}],"severity":"high"},{"content":"As of this writing, Tornado Cash the protocol is no longer under U.S. economic sanctions, having been delisted by OFAC in March 2025 following the Fifth Circuit's Van Loon ruling; co-founder Roman Semenov remains individually sanctioned and criminally charged, and has not been apprehended. In the Netherlands, Alexey Pertsev's 2024 money-laundering conviction and 64-month sentence remain under appeal before the Court of Appeal of 's-Hertogenbosch; reporting from April 2026 indicates the appellate court ordered his continued detention pending that appeal, meaning no final appellate determination has been reported. In the United States, Roman Storm's August 2025 conviction on one count (conspiracy to operate an unlicensed money-transmitting business, maximum five years) stands, but he has not yet been sentenced; the jury's deadlock on the money-laundering and sanctions-violation conspiracy counts left those charges unresolved, Storm has a pending Rule 29 acquittal motion argued in April 2026 and not yet decided, and a retrial on the deadlocked counts has reportedly been scheduled for April 26, 2027, contingent on that motion's resolution.","heading":"Current Legal Status (as of August 2026)","sources":[{"url":"https://www.theblock.co/news/regulation/2026-08-26-tornado-cash-roman-storm-retrial-april-2027-412761","name":"The Block: Tornado Cash developer Roman Storm's retrial pushed back to April 2027","type":"news_article","credibility":2},{"url":"https://dailyhodl.com/2025/02/07/tornado-cash-developer-alexey-pertsev-released-from-dutch-prison-as-he-appeals-five-year-sentence/","name":"The Daily Hodl: Tornado Cash Developer Alexey Pertsev Released From Dutch Prison As He Appeals Five-Year Sentence","type":"news_article","credibility":2},{"url":"https://home.treasury.gov/news/press-releases/sb0057","name":"U.S. Treasury: Tornado Cash Delisting (sb0057)","type":"regulatory","credibility":1},{"url":"https://www.defieducationfund.org/u-s-v-storm-2026-update/","name":"DeFi Education Fund: U.S. v. Storm 2026 Update","type":"research","credibility":2}],"severity":"high"}],"timeline":[{"date":"2019-12-17","event":"Tornado Cash protocol released.","source":"Wikipedia / secondary reporting on Tornado Cash launch","source_url":"https://en.wikipedia.org/wiki/Tornado_Cash","date_evidence":"The initial release was on December 17, 2019."},{"date":"2022-08-08","event":"OFAC designates Tornado Cash and associated Ethereum addresses on the SDN List, citing over $7 billion laundered since 2019 and $455 million laundered by the Lazarus Group.","source":"U.S. Treasury press release jy0916","source_url":"https://home.treasury.gov/news/press-releases/jy0916","date_evidence":"\"Date of Designation: August 8, 2022\""},{"date":"2022-08","event":"Alexey Pertsev arrested in the Netherlands on suspicion of money laundering.","source":"CoinDesk / Axios reporting on Pertsev case","source_url":"https://www.coindesk.com/policy/2024/05/14/tornado-cash-developer-alexey-pertsev-found-guilty-of-money-laundering"},{"date":"2023-08-17","event":"Western District of Texas grants summary judgment to Treasury, upholding the Tornado Cash sanctions in Van Loon v. Department of the Treasury.","source":"Decrypt / legal reporting on Van Loon district court ruling","source_url":"https://decrypt.co/153118/tornado-cash-sanctions-affirmed-by-federal-court","date_evidence":"On August 17, 2023, the US District Court for the Western District of Texas, Austin Division, upheld OFAC's designation of Tornado Cash as a blocked foreign person in Van Loon v. Dept. of the Treasury."},{"date":"2023-08-23","event":"DOJ unseals indictment against Roman Storm and Roman Semenov for money laundering conspiracy, sanctions violations conspiracy, and unlicensed money transmitting; Storm arrested in Washington state; Semenov designated by OFAC.","source":"CNN Business / DOJ","source_url":"https://edition.cnn.com/2023/08/23/business/tornado-cash-crypto-roman-storm/index.html","date_evidence":"On August 23, 2023, Roman Storm was arrested and the U.S. Department of Justice unsealed an indictment in the Southern District of New York charging Storm and a second Tornado Cash cofounder, Roman Semenov."},{"date":"2024-05-14","event":"Dutch court convicts Alexey Pertsev of money laundering and sentences him to 64 months (5 years, 4 months) in prison.","source":"CoinDesk","source_url":"https://www.coindesk.com/policy/2024/05/14/tornado-cash-developer-alexey-pertsev-found-guilty-of-money-laundering","date_evidence":"Judges at the 's-Hertogenbosch Court found Pertsev guilty of money laundering on May 14, 2024 and sentenced him to five years behind bars."},{"date":"2024-11-26","event":"Fifth Circuit Court of Appeals reverses the district court in Van Loon v. Department of the Treasury, holding Tornado Cash's immutable smart contracts are not \"property\" under IEEPA.","source":"Van Loon v. 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