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Tornado Cash is a decentralized, non-custodial cryptocurrency mixing protocol deployed on Ethereum in December 2019, co-founded by Roman Storm, Roman Semenov, and Alexey Pertsev. It was sanctioned by the U.S. Treasury's Office of Foreign Assets Control (OFAC) in August 2022 for allegedly laundering over $7 billion in virtual currency, including hundreds of millions stolen by North Korea's Lazarus Group; the sanctions were later lifted in March 2025 following a Fifth Circuit ruling that immutable smart contracts do not constitute sanctionable 'property' under IEEPA. All three co-founders face or have faced criminal proceedings: Pertsev was convicted in the Netherlands in May 2024 and sentenced to 64 months in prison, Storm was convicted on one of three counts in the U.S. in August 2025, and Semenov remains at large.

Circle Internet Group is the issuer of USDC, the second-largest USD-pegged stablecoin by market capitalization. Circle has faced sustained criticism from blockchain investigator ZachXBT and others for its policy of refusing to freeze USDC linked to hacks or scams without a formal court order or law enforcement mandate, which critics allege has allowed over $420 million in illicit funds to flow freely since 2022. The company went public on the NYSE in June 2025 under the ticker CRCL and received conditional OCC approval for a national trust bank charter in December 2025.