sanctions

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.

Wallex is an Iranian cryptocurrency exchange founded in 2018 in Tehran by graduates of Sharif University of Technology, serving approximately 1 million users as of 2022 and operating as a major domestic crypto-to-rial on/off-ramp. On March 25, 2026, blockchain investigator ZachXBT flagged suspicious fund consolidation activity, prompting both Tether (USDT) and Circle (USDC) to simultaneously blacklist Wallex-linked wallet addresses, leaving approximately $2.49 million stranded on-chain. Wallex operates in a jurisdiction under comprehensive U.S. OFAC sanctions, has been linked by Chainalysis to transactions with a U.S.-sanctioned individual, and suffered a confirmed data breach in 2021 that exposed user credentials.

Token 2049 is one of the world's largest crypto conferences, held annually in Singapore and Dubai by Hong Kong-based BOB Group. The event has faced repeated criticism for insufficient sponsor vetting, most notably when OFAC- and UK-sanctioned Russia-linked stablecoin A7A5 was listed as a platinum sponsor and given a speaking slot at the October 2025 Singapore edition. Separately, in March 2025, on-chain investigator ZachXBT publicly flagged multiple Token 2049 sponsors — including DWF Labs, Bitunix, JuCoin, WEEX, and Spacecoin — for fraud, wash trading, and regulatory non-compliance, warning that conference sponsorship carries no implied credibility.