Audit log

Every state-changing event for Tornado Cash: moderation decisions on community submissions, plus corrections and updates from the news pipeline. URL-based decisions are designed to carry three independent witnesses — the original source, an Internet Archive snapshot, and a Solana memo signed by our publicly-disclosed publisher key. Archive coverage is still being backfilled, so each decision below reports its own snapshot status rather than assuming one exists.

1. #1reviewby reviewerreviewer

   2026-05-14 03:10:22Z
   Score: 25 → 25 (no score change)
   The Tornado Cash investigation page is substantially accurate on the major legal events — the OFAC sanction, Fifth Circuit reversal, March 2025 delisting, Pertsev Dutch conviction, Storm trial verdict, and retrial filing. The most significant factual error appears twice (in both the Founders section and the November 2022 timeline entry): the page incorrectly states that Roman Semenov was individually added to the OFAC SDN List in November 2022, when he was in fact individually sanctioned on August 23, 2023. Additionally, the page's statement that Semenov 'was not removed from the SDN List' during the March 2025 delisting is incomplete — his Cyber-Related designation was removed but DPRK designation maintained. The trial start date of 'late July 2025' is also inaccurate; the trial began July 14, 2025.
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   {"actor":"reviewer","decided_at":"2026-05-14T03:10:22.448Z","decision":"review","investigation_id":"4b6ee26d-dd35-4c7d-b41a-ccf5a997640a","new_score":25,"page_slug":"tornado-cash","prev_score":25,"reason":"The Tornado Cash investigation page is substantially accurate on the major legal events — the OFAC sanction, Fifth Circuit reversal, March 2025 delisting, Pertsev Dutch conviction, Storm trial verdict, and retrial filing. The most significant factual error appears twice (in both the Founders section and the November 2022 timeline entry): the page incorrectly states that Roman Semenov was individually added to the OFAC SDN List in November 2022, when he was in fact individually sanctioned on August 23, 2023. Additionally, the page's statement that Semenov 'was not removed from the SDN List' during the March 2025 delisting is incomplete — his Cyber-Related designation was removed but DPRK designation maintained. The trial start date of 'late July 2025' is also inaccurate; the trial began July 14, 2025.","score_delta":0,"sequence_num":1,"submission_content_hash":null,"submission_id":null,"submission_kind":null,"submission_valence":null,"v":1}

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2. #2review reviseby judgejudge

   2026-05-14 03:10:22Z
   Score: 25 → 13 (-12)
   The page is substantially accurate on major legal events (OFAC sanction, Fifth Circuit reversal, March 2025 delisting, Pertsev conviction, Storm trial verdict). However, two factual errors appear: Roman Semenov was individually added to OFAC's SDN List on August 23, 2023 (claim_findings[7]), not November 2022 as stated in the Founders section and timeline entry (claim_findings[23]). Additionally, Storm's trial began July 14, 2025, not 'late July' (claim_findings[19]). These are clear departures from Tier 1 Treasury and court sources, and the Semenov date error recurs. The disputed/partially-supported percentage is 17%, placing this in the minor-issues band. No coverage gaps rise to priority-high status.
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   {"actor":"judge","decided_at":"2026-05-14T03:10:22.448Z","decision":"review_revise","investigation_id":"4b6ee26d-dd35-4c7d-b41a-ccf5a997640a","new_score":13,"page_slug":"tornado-cash","prev_score":25,"reason":"The page is substantially accurate on major legal events (OFAC sanction, Fifth Circuit reversal, March 2025 delisting, Pertsev conviction, Storm trial verdict). However, two factual errors appear: Roman Semenov was individually added to OFAC's SDN List on August 23, 2023 (claim_findings[7]), not November 2022 as stated in the Founders section and timeline entry (claim_findings[23]). Additionally, Storm's trial began July 14, 2025, not 'late July' (claim_findings[19]). These are clear departures from Tier 1 Treasury and court sources, and the Semenov date error recurs. The disputed/partially-supported percentage is 17%, placing this in the minor-issues band. No coverage gaps rise to priority-high status.","score_delta":-12,"sequence_num":2,"submission_content_hash":null,"submission_id":null,"submission_kind":null,"submission_valence":null,"v":1}

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3. #3publishby system:backfill

   2026-05-30 13:03:51Z
   Score: ? → ? (no score change)
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   {"actor":"system:backfill","investigation_id":"4b6ee26d-dd35-4c7d-b41a-ccf5a997640a","kind":"publish","page_slug":"tornado-cash","published_at":"2026-05-30T13:03:51.208Z","sequence_num":3,"snapshot":{"content_type":"investigation","entity_name":"Tornado Cash","sections":[{"content":"Tornado Cash is a decentralized, non-custodial cryptocurrency mixing protocol deployed on Ethereum and several EVM-compatible blockchains. It was launched in December 2019, with its first fixed-denomination pool deployed in August 2019. The protocol uses zero-knowledge proof cryptography (specifically zk-SNARKs) to sever the on-chain link between depositor and withdrawal addresses. Users deposit a fixed denomination of ETH or ERC-20 tokens into a shared smart-contract pool and receive a cryptographic note; they can later use that note to withdraw funds to a new address with no direct blockchain link to the deposit. In 2020, the core pool smart contracts were made irreversibly immutable by their developers, meaning no individual could alter, pause, or control them after that point. Tornado Cash also issued a governance token (TORN) and operated a decentralized autonomous organization (DAO) for protocol upgrades. Legitimate privacy uses cited by advocates include shielding personal wealth, anonymous charitable donations, and preventing front-running in DeFi. The protocol was the largest cryptocurrency mixer on Ethereum by anonymity-set size at the time of sanctioning.","heading":"Protocol Overview","severity":"medium","sources":[{"credibility":2,"name":"What Is Tornado Cash And How Does It Work? — CoinGecko","type":"research","url":"https://www.coingecko.com/learn/what-is-tornado-cash-and-how-does-it-work"},{"credibility":2,"name":"Tornado Cash — Wikipedia","type":"other","url":"https://en.wikipedia.org/wiki/Tornado_Cash"},{"credibility":2,"name":"Understanding Tornado Cash, Its Sanctions Implications — Chainalysis","type":"research","url":"https://www.chainalysis.com/blog/tornado-cash-sanctions-challenges/"}]},{"content":"Tornado Cash was co-founded by three individuals: Roman Storm (a U.S. resident based in Auburn, Washington), Roman Semenov (a Russian citizen), and Alexey Pertsev (a Russian national residing in the Netherlands). Storm and Semenov are named in a U.S. federal indictment filed August 23, 2023 in the Southern District of New York. Pertsev was arrested by Dutch authorities in August 2022 shortly after the OFAC sanctions. Semenov remains a fugitive, reportedly in Russia, and appears on the FBI's Most Wanted list for white-collar crime. He was also individually added to OFAC's SDN List in November 2022. Storm was arrested in the United States in August 2023 and has stood trial.","heading":"Founders and Key Individuals","severity":"high","sources":[{"credibility":1,"name":"Tornado Cash Founders Charged With Money Laundering — DOJ SDNY","type":"regulatory","url":"https://www.justice.gov/usao-sdny/pr/tornado-cash-founders-charged-money-laundering-and-sanctions-violations"},{"credibility":1,"name":"Treasury Designates Roman Semenov, Co-Founder of Sanctioned Virtual Currency Mixer Tornado Cash","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/jy1702"},{"credibility":1,"name":"ROMAN SEMENOV — FBI Most Wanted","type":"regulatory","url":"https://www.fbi.gov/wanted/wcc/roman-semenov"},{"credibility":2,"name":"US arrests Tornado Cash co-founder, sanctions another who remains at large — The Record","type":"news_article","url":"https://therecord.media/us-arrests-tornado-cash-cofounder"}]},{"content":"On August 8, 2022, the U.S. Treasury Department's Office of Foreign Assets Control (OFAC) designated Tornado Cash under the International Emergency Economic Powers Act (IEEPA), adding it to the Specially Designated Nationals and Blocked Persons (SDN) List. OFAC alleged the protocol had been used to launder more than $7 billion in cryptocurrency since its 2019 launch, including over $455 million stolen by North Korea's Lazarus Group in the March 2022 Ronin/Axie Infinity hack, more than $96 million from the June 2022 Harmony Horizon Bridge heist, and at least $7.8 million from the August 2022 Nomad heist. In November 2022, OFAC updated the designation to include 53 Ethereum smart contract addresses associated with the protocol, including at least 20 immutable smart contracts. The sanctions effectively prohibited any U.S. person from interacting with the protocol and caused major exchanges and front-ends to block access. This marked the first time OFAC sanctioned a set of autonomous smart contracts rather than a named individual or corporate entity.","heading":"OFAC Sanctions — August 2022","severity":"critical","sources":[{"credibility":1,"name":"U.S. Treasury Sanctions Notorious Virtual Currency Mixer Tornado Cash — Treasury.gov","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/jy0916"},{"credibility":2,"name":"OFAC and Tornado Cash: A Timeline of the Events Leading to (and Following) OFAC's Sanctions — Federal Lawyer","type":"news_article","url":"https://federal-lawyer.com/ofac-and-tornado-cash-a-timeline-of-the-events-leading-to-and-following-ofacs-sanctions/"},{"credibility":2,"name":"Tornado Cash Sanctions — Merkle Science","type":"research","url":"https://www.merklescience.com/blog/tornado-cash-sanctions"}]},{"content":"On September 8, 2022, six individuals — including Coinbase employees and Ethereum developers, funded by Coinbase — filed suit in the U.S. District Court for the Western District of Texas (Van Loon v. Department of the Treasury), arguing that OFAC exceeded its statutory authority under IEEPA by sanctioning immutable smart contracts that could not be 'owned' by any person or entity. The plaintiffs also raised First Amendment arguments, contending that prohibiting interaction with open-source code infringed protected speech. On August 17, 2023, District Judge Robert Pitman ruled in favor of the Treasury, finding OFAC's designation lawful and rejecting the constitutional claims. On appeal, the Fifth Circuit Court of Appeals reversed that ruling on November 26, 2024. The appellate court held that Tornado Cash's immutable smart contracts do not constitute 'property' under IEEPA because they are not capable of being owned, controlled, or altered by any individual or entity — and therefore fell outside OFAC's designation authority. The court did not reach the First Amendment question. This ruling was considered a significant limitation on OFAC's ability to police decentralized crypto protocols.","heading":"Van Loon Civil Challenge — Texas District Court and Fifth Circuit","severity":"high","sources":[{"credibility":1,"name":"Fifth Circuit Opinion No. 23-50669 — U.S. Court of Appeals for the Fifth Circuit","type":"court_filing","url":"https://www.ca5.uscourts.gov/opinions/pub/23/23-50669-CV0.pdf"},{"credibility":2,"name":"Federal Appeals Court Tosses OFAC Sanctions on Tornado Cash — Mayer Brown","type":"news_article","url":"https://www.mayerbrown.com/en/insights/publications/2024/12/federal-appeals-court-tosses-ofac-sanctions-on-tornado-cash-and-limits-federal-governments-ability-to-police-crypto-transactions"},{"credibility":2,"name":"Immutable Code Is Not Property: Fifth Circuit Reverses Tornado Cash Sanctions Ruling — Jones Day","type":"news_article","url":"https://www.jonesday.com/en/insights/2024/12/fifth-circuit-reverses-tornado-cash-sanctions-ruling"},{"credibility":2,"name":"Crypto Engineers, Investors Sue US Treasury Over Tornado Cash Sanctions — CoinDesk","type":"news_article","url":"https://www.coindesk.com/policy/2022/09/08/crypto-engineers-investors-sue-us-treasury-over-tornado-cash-sanctions"},{"credibility":2,"name":"Tornado Cash Civil Decision Limits the Reach of the Treasury Department's Actions — EFF","type":"news_article","url":"https://www.eff.org/deeplinks/2023/08/tornado-cash-civil-decision-limits-reach-treasury-departments-actions-while"}]},{"content":"On March 21, 2025, OFAC officially removed Tornado Cash and its associated smart contract addresses from the SDN List. The Treasury stated it exercised discretion in delisting, rather than explicitly conceding the Fifth Circuit ruling compelled the action. In its delisting notice, Treasury stated it remained 'deeply concerned about North Korea's state-sponsored hacking and money laundering campaign' and would continue to monitor transactions that may benefit malicious cyber actors. Notably, Roman Semenov was not removed from the SDN List as part of the delisting. The delisting restored the legal ability of U.S. persons to transact with the Tornado Cash smart contracts, though the criminal prosecution of Roman Storm continued independently of the sanctions status.","heading":"OFAC Delisting — March 2025","severity":"medium","sources":[{"credibility":1,"name":"Tornado Cash Delisting — U.S. Department of the Treasury","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/sb0057"},{"credibility":1,"name":"OFAC Cyber-related Designation Removal — March 21, 2025","type":"regulatory","url":"https://ofac.treasury.gov/recent-actions/20250321"},{"credibility":2,"name":"U.S. Government Removes Tornado Cash Sanctions — CoinDesk","type":"news_article","url":"https://www.coindesk.com/policy/2025/03/21/u-s-government-removes-tornado-cash-sanctions"},{"credibility":2,"name":"Treasury Department Delists Tornado Cash Following the Fifth Circuit's Decision — Steptoe","type":"news_article","url":"https://www.steptoe.com/en/news-publications/international-compliance-blog/treasury-department-delists-tornado-cash-following-the-fifth-circuits-decision.html"},{"credibility":2,"name":"Why OFAC Delisted Tornado Cash — CoinDesk","type":"news_article","url":"https://www.coindesk.com/policy/2025/04/05/why-ofac-delisted-tornado-cash"}]},{"content":"Alexey Pertsev, a Russian national residing in the Netherlands, was arrested by Dutch authorities in August 2022 shortly after OFAC's sanctions designation. On May 14, 2024, the 's-Hertogenbosch court in the Netherlands found Pertsev guilty of money laundering and sentenced him to 64 months (approximately five years and four months) in prison. The court held that Pertsev bore criminal responsibility for failing to prevent criminals, including North Korean state hackers, from using Tornado Cash to launder more than $1.2 billion. Pertsev's defense argued that the open-source and automated nature of the smart contracts meant he could not have controlled how users interacted with the protocol; the court rejected this argument. Pertsev's bail applications were initially denied. On February 7, 2025, a Dutch court granted him conditional release under electronic monitoring to allow him to prepare his appeal. The appeal remains pending before a Dutch appellate court.","heading":"Alexey Pertsev — Netherlands Criminal Proceedings","severity":"critical","sources":[{"credibility":2,"name":"Tornado Cash Developer Alexey Pertsev Found Guilty, Sentenced to 64 Months — Yahoo Finance","type":"news_article","url":"https://finance.yahoo.com/news/tornado-cash-developer-alexey-pertsev-113439000.html"},{"credibility":2,"name":"Tornado Cash developer Alexey Pertsev convicted in The Netherlands — Axios","type":"news_article","url":"https://www.axios.com/2024/05/14/tornado-cash-alexey-pertsev-crypto"},{"credibility":2,"name":"Tornado Cash Developer Alexey Pertsev Released From Dutch Prison As He Appeals — The Daily Hodl","type":"news_article","url":"https://dailyhodl.com/2025/02/07/tornado-cash-developer-alexey-pertsev-released-from-dutch-prison-as-he-appeals-five-year-sentence/"},{"credibility":2,"name":"Dutch Court Sentences Tornado Cash Co-Founder to 5 Years in Prison — The Hacker News","type":"news_article","url":"https://thehackernews.com/2024/05/dutch-court-sentences-tornado-cash-co.html"},{"credibility":2,"name":"Tornado Cash developer Alexey Pertsev appeals conviction — The Block","type":"news_article","url":"https://www.theblock.co/post/294906/tornado-cash-alexey-pertsev-appeals-conviction"}]},{"content":"Roman Storm was arrested in the United States on August 23, 2023. The indictment, filed in the Southern District of New York, charged Storm and co-defendant Roman Semenov with three counts: conspiracy to commit money laundering (maximum 20 years), conspiracy to operate an unlicensed money transmitting business (maximum 5 years), and conspiracy to violate IEEPA/sanctions (maximum 20 years). The government alleged that from 2019 to 2022, Storm and Semenov developed, marketed, and operated Tornado Cash while knowingly facilitating the laundering of over $1 billion in illicit funds, including proceeds from Lazarus Group hacks. Storm pleaded not guilty in September 2023. His trial began in late July 2025 in the SDNY before Judge Katherine Polk Failla. On August 6, 2025, the jury returned a mixed verdict: Storm was convicted on the conspiracy to operate an unlicensed money transmitting business count, but the jury deadlocked on the money laundering and sanctions violations counts. The government sought a retrial on the deadlocked counts; as of March 2026, the DOJ had filed for a retrial with a proposed start date in October 2026. Post-trial motions for acquittal filed by Storm's defense remained pending as of the time of this report. Roman Semenov remains a fugitive and is listed on the FBI's Most Wanted page.","heading":"Roman Storm — U.S. Criminal Prosecution","severity":"critical","sources":[{"credibility":1,"name":"Tornado Cash Founders Charged With Money Laundering and Sanctions Violations — DOJ SDNY","type":"regulatory","url":"https://www.justice.gov/usao-sdny/pr/tornado-cash-founders-charged-money-laundering-and-sanctions-violations"},{"credibility":2,"name":"Tornado Cash Jury Deadlocked on Most Serious Charges, but Convicted Founder Roman Storm — Money Laundering Watch","type":"news_article","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/"},{"credibility":2,"name":"The Tornado Cash Trial's Mixed Verdict: Implications for Developer Liability — Mayer Brown","type":"news_article","url":"https://www.mayerbrown.com/en/insights/publications/2025/08/the-tornado-cash-trials-mixed-verdict-implications-for-developer-liability"},{"credibility":2,"name":"Roman Storm Facing New Trial, DOJ Revives Tornado Cash Prosecution — Bankless","type":"news_article","url":"https://www.bankless.com/read/news/roman-storm-facing-new-trial-doj-revives-tornado-cash-prosecution"},{"credibility":2,"name":"US Government Seeking To Retry Tornado Cash Developer Roman Storm — The Daily Hodl","type":"news_article","url":"https://dailyhodl.com/2026/03/11/us-government-seeking-to-retry-tornado-cash-developer-roman-storm-on-money-laundering-and-sanctions-violation-charges/"},{"credibility":2,"name":"Tornado Cash Developer Roman Storm Pleads Not Guilty — CoinDesk","type":"news_article","url":"https://www.coindesk.com/policy/2023/09/06/tornado-cash-developer-roman-storm-pleads-not-guilty-to-money-laundering-other-charges"}]},{"content":"The Tornado Cash enforcement actions generated substantial legal and policy debate about the limits of government authority over open-source software. Civil liberties organizations including the Electronic Frontier Foundation (EFF) and Coin Center argued that OFAC's sanctions and the DOJ's prosecution raised serious First Amendment concerns, given that writing and publishing code is recognized as protected speech under U.S. precedent. Critics argued that sanctioning immutable, autonomously running smart contracts was unprecedented and legally unsound, since no individual could comply with a cease-and-desist directed at code that no one controls. Lawfare published multiple analyses from differing perspectives, with some scholars arguing the sanctions were an overly creative application of IEEPA and others contending that the protocol was more analogous to a money laundering tool than protected speech. The Fifth Circuit's November 2024 ruling resolved the property question without reaching the First Amendment issue, leaving that constitutional debate unresolved for future cases. The criminal prosecution of Roman Storm introduced a related question: whether a software developer can be held criminally liable for money laundering conducted by third parties using their autonomous, open-source tools. Storm's partial conviction and the pending retrial mean this question remains unsettled in U.S. law.","heading":"Constitutional and Policy Debate","severity":"high","sources":[{"credibility":2,"name":"Tornado Cash Sanctions Are Unduly 'Creative' With the First Amendment — Lawfare","type":"news_article","url":"https://www.lawfaremedia.org/article/tornado-cash-sanctions-are-unduly-creative-first-amendment"},{"credibility":2,"name":"Tornado Cash Is Not Free Speech. It's a Golem — Lawfare","type":"news_article","url":"https://www.lawfaremedia.org/article/tornado-cash-not-free-speech-its-golem"},{"credibility":2,"name":"Coin Center files court brief in defense of Tornado Cash developer — Coin Center","type":"other","url":"https://www.coincenter.org/coin-center-files-a-court-brief-in-defense-of-tornado-cash-developer/"},{"credibility":2,"name":"Tornado Cash Civil Decision Limits the Reach of the Treasury Department's Actions — EFF","type":"news_article","url":"https://www.eff.org/deeplinks/2023/08/tornado-cash-civil-decision-limits-reach-treasury-departments-actions-while"},{"credibility":2,"name":"Tornado Cash Litigation Update — Lawfare","type":"news_article","url":"https://www.lawfaremedia.org/article/tornado-cash-litigation-update"}]},{"content":"A central basis for the U.S. government's actions against Tornado Cash was its alleged use by the Lazarus Group, a North Korean state-sponsored hacking organization already subject to U.S. sanctions. OFAC alleged that Lazarus used Tornado Cash to launder over $455 million stolen in the March 2022 Ronin Network / Axie Infinity hack — the largest known virtual currency theft at the time. Additional Lazarus-linked laundering through Tornado Cash was alleged in connection with the June 2022 Harmony Horizon Bridge hack ($96 million) and the August 2022 Nomad heist ($7.8 million). Blockchain analytics firms including Chainalysis and Elliptic reported that North Korean hackers returned to using Tornado Cash even after sanctions, including an estimated $100 million in ETH from the HTX/HECO breach laundered through the protocol beginning in 2024. The Treasury's March 2025 delisting statement explicitly noted continued concern about North Korean laundering activity.","heading":"North Korea / Lazarus Group Nexus","severity":"critical","sources":[{"credibility":2,"name":"North Korea's Lazarus Group moves funds through Tornado Cash — TRM Labs","type":"research","url":"https://www.trmlabs.com/resources/blog/north-koreas-lazarus-group-moves-funds-through-tornado-cash"},{"credibility":2,"name":"North Korean hackers return to Tornado Cash despite sanctions — Elliptic","type":"research","url":"https://www.elliptic.co/blog/north-korean-hackers-return-to-tornado-cash-despite-sanctions"},{"credibility":2,"name":"U.S. Treasury Lifts Tornado Cash Sanctions Amid North Korea Money Laundering Probe — The Hacker News","type":"news_article","url":"https://thehackernews.com/2025/03/us-treasury-lifts-tornado-cash.html"},{"credibility":2,"name":"Lazarus Group hackers appear to return to Tornado Cash for money laundering — The Record","type":"news_article","url":"https://therecord.media/lazarus-group-north-korea-tornado-cash-money-laundering"}]},{"content":"As of May 2026, OFAC sanctions on Tornado Cash smart contracts have been lifted (effective March 21, 2025). U.S. persons may interact with the protocol without sanctions exposure, though standard anti-money-laundering obligations under FinCEN rules may still apply depending on the nature of use. Roman Storm has been convicted of one count (conspiracy to operate an unlicensed money transmitting business) and faces a retrial on the money laundering and sanctions violation counts, with the DOJ proposing an October 2026 start date. Roman Semenov remains a fugitive and continues to appear on OFAC's SDN List as an individually sanctioned person. Alexey Pertsev was conditionally released from Dutch custody in February 2025 on electronic monitoring and is pursuing an appeal of his 64-month conviction; that appeal remains pending. The broader legal question of developer liability for autonomous open-source code remains unresolved in U.S. courts.","heading":"Current Legal Status (as of May 2026)","severity":"high","sources":[{"credibility":2,"name":"A Legal Whirlwind Settles: Treasury Lifts Sanctions on Tornado Cash — Venable LLP","type":"news_article","url":"https://www.venable.com/insights/publications/2025/04/a-legal-whirlwind-settles-treasury-lifts-sanctions"},{"credibility":3,"name":"Roman Storm Retrial Delayed to December 2025 After Deadlocked Jury — Ainvest","type":"news_article","url":"https://www.ainvest.com/news/roman-storm-retrial-delayed-december-2025-deadlocked-jury-2508/"},{"credibility":2,"name":"Tornado Cash developer Alexey Pertsev gets nod for conditional release — The Block","type":"news_article","url":"https://www.theblock.co/post/339401/tornado-cash-developer-alexey-pertsev-gets-nod-for-conditional-release-from-prison-to-work-on-appeal"},{"credibility":2,"name":"US Government Seeking To Retry Tornado Cash Developer Roman Storm — The Daily Hodl","type":"news_article","url":"https://dailyhodl.com/2026/03/11/us-government-seeking-to-retry-tornado-cash-developer-roman-storm-on-money-laundering-and-sanctions-violation-charges/"}]},{"body":"Tornado Cash is an open-source, non-custodial cryptocurrency tumbler (mixer) built on the Ethereum blockchain. It was deployed in December 2019 and co-founded by Roman Storm (a Washington State resident), Roman Semenov (a Russian citizen), and Alexey Pertsev (a Russian national residing in the Netherlands). The protocol uses zero-knowledge proofs (zk-SNARKs) to break the on-chain link between deposit and withdrawal addresses, allowing users to deposit a fixed denomination of ETH or ERC-20 tokens and later withdraw the same amount to a different address with no traceable on-chain connection. In May 2020, the founding team relinquished administrative control over the core protocol through a Trusted Setup Ceremony, rendering the primary smart contracts immutable. A governance token, TORN, was launched in 2021 to allow community voting on protocol changes. Tornado Cash received over $7.6 billion worth of Ethereum since its August 2019 activation, according to Chainalysis data cited in OFAC's 2022 designation.","heading":"Overview and Protocol Description","severity":"high","sources":[{"credibility":1,"name":"U.S. Treasury Sanctions Notorious Virtual Currency Mixer Tornado Cash","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/jy0916"},{"credibility":2,"name":"OFAC Sanctions Popular Ethereum Mixer Tornado Cash for Laundering Crypto Stolen by North Korea's Lazarus Group - Chainalysis","type":"research","url":"https://www.chainalysis.com/blog/tornado-cash-ofac-designation-sanctions/"},{"credibility":2,"name":"Tornado Cash - Wikipedia","type":"other","url":"https://en.wikipedia.org/wiki/Tornado_Cash"}]},{"body":"On August 8, 2022, OFAC designated Tornado Cash and added 45 Ethereum addresses to its Specially Designated Nationals and Blocked Persons (SDN) list under the authority of the International Emergency Economic Powers Act (IEEPA) and the North Korea Sanctions and Policy Enhancement Act. In November 2022, OFAC updated the designation to encompass 53 Ethereum addresses, including at least 20 immutable smart contracts. The designation prohibited U.S. persons and entities subject to U.S. jurisdiction from transacting with any of the listed addresses.\n\nKey sanctioned Ethereum contract addresses included the following Tornado Cash pool contracts: 0x12D66f87A04A9E220743712cE6d9bB1B5616B8Fc (0.1 ETH pool), 0x47CE0C6eD5B0Ce3d3A51fdb1C52DC66a7c3c2936 (1 ETH pool), 0x910Cbd523D972eb0a6f4cAe4618aD62622b39Dbf (10 ETH pool), 0xA160cdAB225685dA1d56aa342Ad8841c3b53f291 (100 ETH pool), 0xd90e2f925DA726b50C4Ed8D0Fb90Ad053324F31b (Router), 0x722122dF12D4e14e13Ac3b6895a86e84145b6967 (Proxy), 0x8589427373D6D84E98730D7795D8f6f8731FDA16, 0xDD4c48C0B24039969fC16D1cdF626eaB821d3384, 0xd96f2B1c14Db8458374d9Aca76E26c3D18364307, 0x4736dCf1b7A3d580672CcE6E7c65cd5cc9cFBa9D, and 0xD4B88Df4D29F5CedD6857912842cff3b20C8Cfa3, among others. USDC-denominated and other ERC-20 denomination pools were also included in the full 53-address SDN listing.\n\nOFAC stated that Tornado Cash had been used to launder more than $7 billion in virtual currency since its 2019 launch, including over $455 million stolen by North Korea's Lazarus Group from Axie Infinity's Ronin Bridge, and more than $96 million from the June 2022 Harmony Horizon Bridge hack.","heading":"OFAC Sanctions (August 2022) and Sanctioned Contract Addresses","severity":"critical","sources":[{"credibility":1,"name":"U.S. Treasury Sanctions Notorious Virtual Currency Mixer Tornado Cash","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/jy0916"},{"credibility":1,"name":"Cyber-related Designation - OFAC August 8, 2022","type":"regulatory","url":"https://ofac.treasury.gov/recent-actions/20220808"},{"credibility":2,"name":"OFAC Sanctions Popular Ethereum Mixer Tornado Cash - Chainalysis","type":"research","url":"https://www.chainalysis.com/blog/tornado-cash-ofac-designation-sanctions/"},{"credibility":1,"name":"Tornado.Cash: 0.1 ETH Pool - Etherscan","type":"on_chain","url":"https://etherscan.io/address/0x12d66f87a04a9e220743712ce6d9bb1b5616b8fc"},{"credibility":1,"name":"Tornado.Cash: 1 ETH Pool - Etherscan","type":"on_chain","url":"https://etherscan.io/address/0x47CE0C6eD5B0Ce3d3A51fdb1C52DC66a7c3c2936"},{"credibility":1,"name":"Tornado.Cash: 10 ETH Pool - Etherscan","type":"on_chain","url":"https://etherscan.io/address/0x910cbd523d972eb0a6f4cae4618ad62622b39dbf"},{"credibility":1,"name":"Tornado.Cash: 100 ETH Pool - Etherscan","type":"on_chain","url":"https://etherscan.io/address/0xA160cdAB225685dA1d56aa342Ad8841c3b53f291"}]},{"body":"OFAC and the DOJ have alleged that North Korea's Lazarus Group, a state-sponsored cybercrime organization sanctioned by the U.S. Treasury, used Tornado Cash as a primary laundering vehicle for funds stolen in multiple high-profile cryptocurrency heists. Elliptic's research estimates the Lazarus Group sent more than $555 million through Tornado Cash in total, including over $468 million from the Ronin Bridge hack and approximately $96 million from the Harmony Horizon Bridge hack. OFAC's August 2022 designation specifically cited Tornado Cash's alleged processing of $455 million stolen in the Ronin/Axie Infinity hack — at the time the largest known cryptocurrency heist — and the $96 million Harmony Horizon Bridge theft. The protocol's lack of know-your-customer (KYC) controls or transaction screening was identified by regulators as enabling systematic use by sanctioned entities. According to Chainalysis data, approximately 18% of all funds received by Tornado Cash originated from sanctioned entities, and just under 11% were funds stolen from other cryptocurrency platforms.","heading":"North Korea Lazarus Group Connections","severity":"critical","sources":[{"credibility":1,"name":"U.S. Treasury Sanctions Notorious Virtual Currency Mixer Tornado Cash","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/jy0916"},{"credibility":2,"name":"Tornado Cash Devs Charged With Helping Hackers Launder $1B, Including Infamous North Korean Attacks - CoinDesk","type":"news_article","url":"https://www.coindesk.com/policy/2023/08/23/tornado-cash-devs-arrested-on-money-laundering-sanctions-violation-grounds-over-alleged-1b-moved"},{"credibility":2,"name":"North Korea's Lazarus Group moves funds through Tornado Cash - TRM Labs","type":"research","url":"https://www.trmlabs.com/resources/blog/north-koreas-lazarus-group-moves-funds-through-tornado-cash"},{"credibility":2,"name":"Understanding Tornado Cash, Its Sanctions Implications, and Key Compliance Questions - Chainalysis","type":"research","url":"https://www.chainalysis.com/blog/tornado-cash-sanctions-challenges/"}]},{"body":"On August 23, 2023, the U.S. Attorney's Office for the Southern District of New York unsealed an indictment charging co-founders Roman Storm and Roman Semenov with three counts: conspiracy to commit money laundering (maximum 20 years), conspiracy to commit sanctions violations (maximum 20 years), and conspiracy to operate an unlicensed money transmitting business (maximum 5 years). On the same day, Roman Storm was arrested in Washington State, and the U.S. Treasury separately designated Roman Semenov as a Specially Designated National. Semenov, a Russian citizen, remains at large as of the time of reporting.\n\nThe indictment alleged that from 2019 to 2022, Storm and Semenov developed, marketed, and operated Tornado Cash with knowledge that a substantial portion of processed funds were criminal proceeds, including funds from the Lazarus Group. The DOJ alleged the protocol facilitated more than $1 billion in money laundering transactions overall.\n\nStorm's trial in the Southern District of New York concluded on August 6, 2025, with a split verdict: the jury convicted Storm on the count of conspiracy to operate an unlicensed money transmitting business, but deadlocked on the two more serious charges of money laundering conspiracy and sanctions violation conspiracy. The jury deadlock on the more serious counts resulted in no verdict on those charges. Storm was allowed to remain free on bail pending sentencing, with a post-trial motion hearing scheduled for December 18, 2025. Sentencing on the single conviction has not yet been formally scheduled as of the time of this report.","heading":"Criminal Charges: Roman Storm and Roman Semenov (United States)","severity":"critical","sources":[{"credibility":1,"name":"IRS Criminal Investigation Media Release - Tornado Cash Founders Charged","type":"regulatory","url":"https://www.irs.gov/pub/irs-ci/j5-media-release-8-29-2023.pdf"},{"credibility":1,"name":"Treasury Designates Roman Semenov, Co-Founder of Sanctioned Virtual Currency Mixer Tornado Cash","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/jy1702"},{"credibility":2,"name":"Tornado Cash Jury Deadlocked on Most Serious Charges, but Convicted Founder Roman Storm - Money Laundering Watch","type":"news_article","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/"},{"credibility":1,"name":"Founder of Tornado Cash crypto mixing service convicted of knowingly transmitting criminal proceeds - IRS","type":"regulatory","url":"https://www.irs.gov/compliance/criminal-investigation/founder-of-tornado-cash-crypto-mixing-service-convicted-of-knowingly-transmitting-criminal-proceeds"},{"credibility":2,"name":"Tornado Cash Trial Concludes: Roman Storm Found Guilty On One Of Three Counts - Bitcoin Magazine","type":"news_article","url":"https://bitcoinmagazine.com/news/tornado-cash-trial-concludes-roman-storm-found-guilty-of-one-of-three-counts"},{"credibility":2,"name":"OFAC Sanctions Tornado Cash Founder Roman Semenov - Chainalysis","type":"research","url":"https://www.chainalysis.com/blog/ofac-sanctions-roman-semenov-tornado-cash/"}]},{"body":"Alexey Pertsev, a Russian national residing in the Netherlands and the third co-founder of Tornado Cash, was arrested in Amsterdam on August 10, 2022 — two days after the OFAC sanctions designation — by Dutch authorities on suspicion of involvement in concealing criminal financial flows and facilitating money laundering through the Tornado Cash protocol. After being held in pretrial detention for approximately eight months, Pertsev stood trial before the 's-Hertogenbosch District Court in the Netherlands.\n\nOn May 14, 2024, the Dutch court found Pertsev guilty of money laundering, specifically determining that he had 'made a habit of committing money laundering' between July 9, 2019 and August 10, 2022 and that he knew the platform was being used for illicit purposes. The court determined that Tornado Cash lacked any barriers to prevent money laundering. Pertsev was sentenced to 64 months (5 years and 4 months) in prison. The court also ordered forfeiture of seized assets, including a Porsche and cryptocurrency worth approximately €1.9 million ($2.1 million), which would not be returned. The approximately eight months Pertsev had already served in pretrial detention were to be deducted from the sentence. Pertsev filed an appeal, and as of early 2026 reporting, he was transferred to supervised release pending that appeal.","heading":"Criminal Conviction: Alexey Pertsev (Netherlands)","severity":"critical","sources":[{"credibility":2,"name":"Tornado Cash Developer Alexey Pertsev Found Guilty, Sentenced to 64 Months in Prison by Dutch Court - CoinDesk","type":"news_article","url":"https://www.coindesk.com/policy/2024/05/14/tornado-cash-developer-alexey-pertsev-found-guilty-of-money-laundering"},{"credibility":2,"name":"Tornado Cash developer Alexey Pertsev convicted in The Netherlands - Axios","type":"news_article","url":"https://www.axios.com/2024/05/14/tornado-cash-alexey-pertsev-crypto"},{"credibility":2,"name":"Dutch Court Sentences Tornado Cash Co-Founder to 5 Years in Prison for Money Laundering - The Hacker News","type":"news_article","url":"https://thehackernews.com/2024/05/dutch-court-sentences-tornado-cash-co.html"},{"credibility":2,"name":"Tornado Cash Developer Alexey Pertsev Leaving Prison on Supervised Release - Decrypt","type":"news_article","url":"https://decrypt.co/304723/tornado-cash-developer-alexey-perstev-leaving-prison"}]},{"body":"In November 2022, a group of Tornado Cash users filed suit against the U.S. Treasury in Van Loon v. Department of the Treasury, challenging OFAC's authority to sanction immutable smart contracts. A federal district court in Texas initially upheld the sanctions in 2023. On November 26, 2024, a unanimous three-judge panel of the U.S. Court of Appeals for the Fifth Circuit reversed the district court's ruling in Van Loon et al. v. Dep't of the Treasury, No. 23-50669. The Fifth Circuit held that Tornado Cash's immutable smart contracts do not constitute 'property' under IEEPA because they cannot be owned, controlled, or altered by any individual or entity, and that OFAC had therefore exceeded its statutory authority in designating them. The court cited the Supreme Court's 2024 ruling in Loper Bright v. Raimondo in declining to defer to OFAC's agency interpretation.\n\nThe Fifth Circuit's ruling left in place the individual sanctions against Roman Semenov as a person. Following the ruling, on March 21, 2025, OFAC officially removed Tornado Cash and its associated addresses from the SDN list, reversing the August 2022 designation. The delisting did not affect the ongoing criminal proceedings against Storm and Semenov, nor the separate Dutch proceedings against Pertsev.","heading":"Fifth Circuit Ruling and OFAC Sanctions Removal","severity":"high","sources":[{"credibility":1,"name":"Fifth Circuit Opinion - Van Loon v. Department of the Treasury, No. 23-50669","type":"court_filing","url":"https://www.ca5.uscourts.gov/opinions/pub/23/23-50669-CV0.pdf"},{"credibility":2,"name":"Immutable Code Is Not Property: Fifth Circuit Reverses Tornado Cash Sanctions Ruling - Jones Day","type":"news_article","url":"https://www.jonesday.com/en/insights/2024/12/fifth-circuit-reverses-tornado-cash-sanctions-ruling"},{"credibility":1,"name":"Tornado Cash Delisting - U.S. Department of the Treasury","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/sb0057"},{"credibility":1,"name":"Cyber-related Designation Removal; North Korea Designation Update and Removal - OFAC March 21, 2025","type":"regulatory","url":"https://ofac.treasury.gov/recent-actions/20250321"},{"credibility":2,"name":"U.S. Government Removes Tornado Cash Sanctions - CoinDesk","type":"news_article","url":"https://www.coindesk.com/policy/2025/03/21/u-s-government-removes-tornado-cash-sanctions"},{"credibility":2,"name":"Federal Appeals Court Tosses OFAC Sanctions on Tornado Cash - Mayer Brown","type":"news_article","url":"https://www.mayerbrown.com/en/insights/publications/2024/12/federal-appeals-court-tosses-ofac-sanctions-on-tornado-cash-and-limits-federal-governments-ability-to-police-crypto-transactions"}]},{"body":"According to Chainalysis analysis published at the time of the OFAC designation, Tornado Cash received over $7.6 billion worth of Ethereum since its August 2019 deployment. Approximately 30% of funds processed were tied to illicit actors. Of total volume, roughly 18% originated from sanctioned entities and approximately 11% from funds stolen from other cryptocurrency platforms. Following the August 2022 OFAC sanctions, traffic to Tornado Cash declined by approximately 93% according to on-chain analytics reported by CryptoNews.net. Despite the sanctions, North Korean Lazarus Group hackers were subsequently reported by Elliptic and Recorded Future to have returned to using Tornado Cash after the sanctions period, including in connection with the $1.5 billion Bybit hack in early 2025. The protocol's structure as immutable, autonomous code made it technically impossible for the founding team to block specific wallet addresses after the Trusted Setup Ceremony in 2020, a fact that became central both to the Fifth Circuit's legal reasoning and to Storm's defense at trial.","heading":"Protocol Use for Illicit Finance and Impact","severity":"high","sources":[{"credibility":2,"name":"Understanding Tornado Cash, Its Sanctions Implications, and Key Compliance Questions - Chainalysis","type":"research","url":"https://www.chainalysis.com/blog/tornado-cash-sanctions-challenges/"},{"credibility":3,"name":"Tornado Cash traffic tanks 93% in the wake of sanctions, Chainalysis data shows","type":"news_article","url":"https://cryptonews.net/news/security/28643025/"},{"credibility":2,"name":"Lazarus Group hackers appear to return to Tornado Cash for money laundering - The Record from Recorded Future News","type":"news_article","url":"https://therecord.media/lazarus-group-north-korea-tornado-cash-money-laundering"},{"credibility":2,"name":"North Korean hackers return to Tornado Cash despite sanctions - Elliptic","type":"research","url":"https://www.elliptic.co/blog/north-korean-hackers-return-to-tornado-cash-despite-sanctions"}]},{"body":"The Tornado Cash criminal proceedings — particularly the split verdict against Roman Storm in August 2025 — have generated significant debate in the cryptocurrency and legal communities regarding the scope of developer liability for permissionless, open-source protocols. Storm's conviction on the unlicensed money transmitting business count, alongside the jury's deadlock on the money laundering and sanctions counts, was described by some legal commentators as a 'mixed verdict' with significant implications. Storm's defense argued that he was a software developer whose only agreement was to build financial privacy tools, and that holding developers liable for how autonomous code is used sets a dangerous precedent. The DeFi Education Fund, Coin Center, and other advocacy organizations filed amicus briefs or published analysis arguing that the prosecution threatened open-source software development broadly. Conversely, federal prosecutors and the IRS Criminal Investigation division argued that Storm had direct knowledge of illicit use and deliberately chose not to implement available compliance controls.","heading":"Implications for Developer Liability","severity":"medium","sources":[{"credibility":2,"name":"The Tornado Cash Trial's Mixed Verdict: Implications for Developer Liability - Mayer Brown","type":"news_article","url":"https://www.mayerbrown.com/en/insights/publications/2025/08/the-tornado-cash-trials-mixed-verdict-implications-for-developer-liability"},{"credibility":2,"name":"US v. Storm: Background & Timeline - DeFi Education Fund","type":"other","url":"https://www.defieducationfund.org/us-v-storm-background-timeline/"},{"credibility":2,"name":"Analysis: What is and what is not a sanctionable entity in the Tornado Cash case - Coin Center","type":"research","url":"https://coincenter.org/analysis-what-is-and-what-is-not-a-sanctionable-entity-in-the-tornado-cash-case/"},{"credibility":2,"name":"Tornado Cash Trial Ends in Split Verdict, Leaving Crypto Mixer Liability Unresolved - National Law Review","type":"news_article","url":"https://natlawreview.com/article/tornado-cash-and-legality-mixers"}]}],"sources_used":[{"archive_timestamp":null,"archive_url":null,"credibility":1,"name":"U.S. Treasury Sanctions Notorious Virtual Currency Mixer Tornado Cash","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/jy0916"},{"archive_timestamp":"2026-04-21T11:17:10+00:00","archive_url":"http://web.archive.org/web/20260421111710/https://ofac.treasury.gov/recent-actions/20250321","credibility":1,"name":"OFAC Cyber-related Designation Removal — March 21, 2025","type":"regulatory","url":"https://ofac.treasury.gov/recent-actions/20250321"},{"archive_timestamp":"2026-03-30T00:07:39+00:00","archive_url":"http://web.archive.org/web/20260330000739/https://home.treasury.gov/news/press-releases/sb0057","credibility":1,"name":"Tornado Cash Delisting — U.S. Department of the Treasury","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/sb0057"},{"archive_timestamp":null,"archive_url":null,"credibility":1,"name":"Treasury Designates Roman Semenov, Co-Founder of Sanctioned Virtual Currency Mixer Tornado Cash","type":"regulatory","url":"https://home.treasury.gov/news/press-releases/jy1702"},{"archive_timestamp":"2026-04-04T13:26:29+00:00","archive_url":"http://web.archive.org/web/20260404132629/https://www.justice.gov/usao-sdny/pr/tornado-cash-founders-charged-money-laundering-and-sanctions-violations","credibility":1,"name":"Tornado Cash Founders Charged With Money Laundering and Sanctions Violations — DOJ SDNY","type":"regulatory","url":"https://www.justice.gov/usao-sdny/pr/tornado-cash-founders-charged-money-laundering-and-sanctions-violations"},{"archive_timestamp":"2026-05-14T07:08:07+00:00","archive_url":"http://web.archive.org/web/20260514070807/https://www.fbi.gov/wanted/wcc/roman-semenov","credibility":1,"name":"ROMAN SEMENOV — FBI Most Wanted","type":"regulatory","url":"https://www.fbi.gov/wanted/wcc/roman-semenov"},{"archive_timestamp":"2026-05-18T16:42:37+00:00","archive_url":"http://web.archive.org/web/20260518164237/https://www.ca5.uscourts.gov/opinions/pub/23/23-50669-CV0.pdf","credibility":1,"name":"Fifth Circuit Opinion No. 23-50669 — Van Loon v. Department of the Treasury","type":"court_filing","url":"https://www.ca5.uscourts.gov/opinions/pub/23/23-50669-CV0.pdf"},{"archive_timestamp":null,"archive_url":null,"credibility":2,"name":"Tornado Cash developer Alexey Pertsev convicted in The Netherlands — Axios","type":"news_article","url":"https://www.axios.com/2024/05/14/tornado-cash-alexey-pertsev-crypto"},{"archive_timestamp":"2026-02-11T16:14:19+00:00","archive_url":"http://web.archive.org/web/20260211161419/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/","credibility":2,"name":"Tornado Cash Jury Deadlocked on Most Serious Charges — Money Laundering Watch","type":"news_article","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/"},{"archive_timestamp":"2026-01-13T06:28:57+00:00","archive_url":"http://web.archive.org/web/20260113062857/https://www.mayerbrown.com/en/insights/publications/2025/08/the-tornado-cash-trials-mixed-verdict-implications-for-developer-liability","credibility":2,"name":"The Tornado Cash Trial's Mixed Verdict: Implications for Developer Liability — Mayer Brown","type":"news_article","url":"https://www.mayerbrown.com/en/insights/publications/2025/08/the-tornado-cash-trials-mixed-verdict-implications-for-developer-liability"},{"archive_timestamp":"2025-10-07T11:47:54+00:00","archive_url":"http://web.archive.org/web/20251007114754/https://www.mayerbrown.com/en/insights/publications/2024/12/federal-appeals-court-tosses-ofac-sanctions-on-tornado-cash-and-limits-federal-governments-ability-to-police-crypto-transactions","credibility":2,"name":"Federal Appeals Court Tosses OFAC Sanctions on Tornado Cash — Mayer Brown","type":"news_article","url":"https://www.mayerbrown.com/en/insights/publications/2024/12/federal-appeals-court-tosses-ofac-sanctions-on-tornado-cash-and-limits-federal-governments-ability-to-police-crypto-transactions"},{"archive_timestamp":"2026-02-07T20:21:56+00:00","archive_url":"http://web.archive.org/web/20260207202156/https://www.jonesday.com/en/insights/2024/12/fifth-circuit-reverses-tornado-cash-sanctions-ruling","credibility":2,"name":"Immutable Code Is Not Property: Fifth Circuit Reverses Tornado Cash Sanctions Ruling — Jones Day","type":"news_article","url":"https://www.jonesday.com/en/insights/2024/12/fifth-circuit-reverses-tornado-cash-sanctions-ruling"},{"archive_timestamp":null,"archive_url":null,"credibility":2,"name":"U.S. Government Removes Tornado Cash Sanctions — CoinDesk","type":"news_article","url":"https://www.coindesk.com/policy/2025/03/21/u-s-government-removes-tornado-cash-sanctions"},{"archive_timestamp":"2026-03-08T13:36:34+00:00","archive_url":"http://web.archive.org/web/20260308133634/https://www.trmlabs.com/resources/blog/north-koreas-lazarus-group-moves-funds-through-tornado-cash","credibility":2,"name":"North Korea's Lazarus Group moves funds through Tornado Cash — TRM Labs","type":"research","url":"https://www.trmlabs.com/resources/blog/north-koreas-lazarus-group-moves-funds-through-tornado-cash"},{"archive_timestamp":"2026-03-01T03:45:59+00:00","archive_url":"http://web.archive.org/web/20260301034559/https://www.elliptic.co/blog/north-korean-hackers-return-to-tornado-cash-despite-sanctions","credibility":2,"name":"North Korean hackers return to Tornado Cash despite sanctions — Elliptic","type":"research","url":"https://www.elliptic.co/blog/north-korean-hackers-return-to-tornado-cash-despite-sanctions"},{"archive_timestamp":"2026-02-12T00:35:50+00:00","archive_url":"http://web.archive.org/web/20260212003550/https://www.lawfaremedia.org/article/tornado-cash-sanctions-are-unduly-creative-first-amendment","credibility":2,"name":"Tornado Cash Sanctions Are Unduly 'Creative' With the First Amendment — Lawfare","type":"news_article","url":"https://www.lawfaremedia.org/article/tornado-cash-sanctions-are-unduly-creative-first-amendment"},{"archive_timestamp":"2026-03-23T17:20:54+00:00","archive_url":"http://web.archive.org/web/20260323172054/https://www.eff.org/deeplinks/2023/08/tornado-cash-civil-decision-limits-reach-treasury-departments-actions-while","credibility":2,"name":"Tornado Cash Civil Decision Limits the Reach of the Treasury Department's Actions — EFF","type":"news_article","url":"https://www.eff.org/deeplinks/2023/08/tornado-cash-civil-decision-limits-reach-treasury-departments-actions-while"},{"archive_timestamp":null,"archive_url":null,"credibility":2,"name":"Coin Center files court brief in defense of Tornado Cash developer","type":"other","url":"https://www.coincenter.org/coin-center-files-a-court-brief-in-defense-of-tornado-cash-developer/"},{"archive_timestamp":"2025-08-12T13:24:27+00:00","archive_url":"http://web.archive.org/web/20250812132427/https://www.lawfaremedia.org/article/tornado-cash-litigation-update","credibility":2,"name":"Tornado Cash Litigation Update — Lawfare","type":"news_article","url":"https://www.lawfaremedia.org/article/tornado-cash-litigation-update"},{"archive_timestamp":"2026-04-09T21:40:11+00:00","archive_url":"http://web.archive.org/web/20260409214011/https://therecord.media/us-arrests-tornado-cash-cofounder","credibility":2,"name":"US arrests Tornado Cash co-founder, sanctions another who remains at large — The Record","type":"news_article","url":"https://therecord.media/us-arrests-tornado-cash-cofounder"},{"archive_timestamp":"2026-01-22T17:18:37+00:00","archive_url":"http://web.archive.org/web/20260122171837/https://thehackernews.com/2024/05/dutch-court-sentences-tornado-cash-co.html","credibility":2,"name":"Dutch Court Sentences Tornado Cash Co-Founder to 5 Years in Prison — The Hacker News","type":"news_article","url":"https://thehackernews.com/2024/05/dutch-court-sentences-tornado-cash-co.html"},{"archive_timestamp":"2025-09-12T12:33:49+00:00","archive_url":"http://web.archive.org/web/20250912123349/https://dailyhodl.com/2025/02/07/tornado-cash-developer-alexey-pertsev-released-from-dutch-prison-as-he-appeals-five-year-sentence/","credibility":2,"name":"Tornado Cash Developer Alexey Pertsev Released From Dutch Prison — The Daily Hodl","type":"news_article","url":"https://dailyhodl.com/2025/02/07/tornado-cash-developer-alexey-pertsev-released-from-dutch-prison-as-he-appeals-five-year-sentence/"},{"archive_timestamp":"2026-03-12T03:18:20+00:00","archive_url":"http://web.archive.org/web/20260312031820/https://dailyhodl.com/2026/03/11/us-government-seeking-to-retry-tornado-cash-developer-roman-storm-on-money-laundering-and-sanctions-violation-charges/","credibility":2,"name":"US Government Seeking To Retry Tornado Cash Developer Roman Storm — The Daily Hodl","type":"news_article","url":"https://dailyhodl.com/2026/03/11/us-government-seeking-to-retry-tornado-cash-developer-roman-storm-on-money-laundering-and-sanctions-violation-charges/"},{"archive_timestamp":null,"archive_url":null,"credibility":2,"name":"Treasury Department Delists Tornado Cash Following the Fifth Circuit's Decision — Steptoe","type":"news_article","url":"https://www.steptoe.com/en/news-publications/international-compliance-blog/treasury-department-delists-tornado-cash-following-the-fifth-circuits-decision.html"},{"archive_timestamp":"2026-03-18T11:23:50+00:00","archive_url":"http://web.archive.org/web/20260318112350/https://www.defieducationfund.org/us-v-storm-background-timeline/","credibility":2,"name":"US v. Storm: Background & Timeline — DeFi Education Fund","type":"other","url":"https://www.defieducationfund.org/us-v-storm-background-timeline/"},{"archive_timestamp":"2025-12-30T02:04:34+00:00","archive_url":"http://web.archive.org/web/20251230020434/https://www.coingecko.com/learn/what-is-tornado-cash-and-how-does-it-work","credibility":2,"name":"What Is Tornado Cash And How Does It Work? — CoinGecko","type":"research","url":"https://www.coingecko.com/learn/what-is-tornado-cash-and-how-does-it-work"},{"archive_timestamp":"2026-04-21T10:49:32+00:00","archive_url":"http://web.archive.org/web/20260421104932/https://ofac.treasury.gov/recent-actions/20220808","name":"https://ofac.treasury.gov/recent-actions/20220808","url":"https://ofac.treasury.gov/recent-actions/20220808"},{"archive_timestamp":"2026-02-07T14:03:05+00:00","archive_url":"http://web.archive.org/web/20260207140305/https://www.irs.gov/pub/irs-ci/j5-media-release-8-29-2023.pdf","name":"https://www.irs.gov/pub/irs-ci/j5-media-release-8-29-2023.pdf","url":"https://www.irs.gov/pub/irs-ci/j5-media-release-8-29-2023.pdf"},{"archive_timestamp":"2026-02-07T21:24:32+00:00","archive_url":"http://web.archive.org/web/20260207212432/https://www.irs.gov/compliance/criminal-investigation/founder-of-tornado-cash-crypto-mixing-service-convicted-of-knowingly-transmitting-criminal-proceeds","name":"https://www.irs.gov/compliance/criminal-investigation/founder-of-tornado-cash-crypto-mixing-service-convicted-of-knowingly-transmitting-criminal-proceeds","url":"https://www.irs.gov/compliance/criminal-investigation/founder-of-tornado-cash-crypto-mixing-service-convicted-of-knowingly-transmitting-criminal-proceeds"},{"archive_timestamp":"2026-03-03T01:47:26+00:00","archive_url":"http://web.archive.org/web/20260303014726/https://www.chainalysis.com/blog/tornado-cash-ofac-designation-sanctions/","name":"https://www.chainalysis.com/blog/tornado-cash-ofac-designation-sanctions/","url":"https://www.chainalysis.com/blog/tornado-cash-ofac-designation-sanctions/"},{"archive_timestamp":"2026-03-11T00:53:08+00:00","archive_url":"http://web.archive.org/web/20260311005308/https://www.chainalysis.com/blog/tornado-cash-sanctions-challenges/","name":"https://www.chainalysis.com/blog/tornado-cash-sanctions-challenges/","url":"https://www.chainalysis.com/blog/tornado-cash-sanctions-challenges/"},{"archive_timestamp":"2026-02-15T22:30:31+00:00","archive_url":"http://web.archive.org/web/20260215223031/https://www.chainalysis.com/blog/ofac-sanctions-roman-semenov-tornado-cash/","name":"https://www.chainalysis.com/blog/ofac-sanctions-roman-semenov-tornado-cash/","url":"https://www.chainalysis.com/blog/ofac-sanctions-roman-semenov-tornado-cash/"},{"archive_timestamp":null,"archive_url":null,"name":"https://www.coindesk.com/policy/2023/08/23/tornado-cash-devs-arrested-on-money-laundering-sanctions-violation-grounds-over-alleged-1b-moved","url":"https://www.coindesk.com/policy/2023/08/23/tornado-cash-devs-arrested-on-money-laundering-sanctions-violation-grounds-over-alleged-1b-moved"},{"archive_timestamp":null,"archive_url":null,"name":"https://www.coindesk.com/policy/2024/05/14/tornado-cash-developer-alexey-pertsev-found-guilty-of-money-laundering","url":"https://www.coindesk.com/policy/2024/05/14/tornado-cash-developer-alexey-pertsev-found-guilty-of-money-laundering"},{"archive_timestamp":null,"archive_url":null,"name":"https://decrypt.co/304723/tornado-cash-developer-alexey-perstev-leaving-prison","url":"https://decrypt.co/304723/tornado-cash-developer-alexey-perstev-leaving-prison"},{"archive_timestamp":"2026-03-17T03:05:32+00:00","archive_url":"http://web.archive.org/web/20260317030532/https://bitcoinmagazine.com/news/tornado-cash-trial-concludes-roman-storm-found-guilty-of-one-of-three-counts","name":"https://bitcoinmagazine.com/news/tornado-cash-trial-concludes-roman-storm-found-guilty-of-one-of-three-counts","url":"https://bitcoinmagazine.com/news/tornado-cash-trial-concludes-roman-storm-found-guilty-of-one-of-three-counts"},{"archive_timestamp":null,"archive_url":null,"name":"https://natlawreview.com/article/tornado-cash-and-legality-mixers","url":"https://natlawreview.com/article/tornado-cash-and-legality-mixers"},{"archive_timestamp":"2026-03-23T05:18:54+00:00","archive_url":"http://web.archive.org/web/20260323051854/https://www.coincenter.org/analysis-what-is-and-what-is-not-a-sanctionable-entity-in-the-tornado-cash-case/","name":"https://coincenter.org/analysis-what-is-and-what-is-not-a-sanctionable-entity-in-the-tornado-cash-case/","url":"https://coincenter.org/analysis-what-is-and-what-is-not-a-sanctionable-entity-in-the-tornado-cash-case/"},{"archive_timestamp":"2025-12-27T09:42:58+00:00","archive_url":"http://web.archive.org/web/20251227094258/https://therecord.media/lazarus-group-north-korea-tornado-cash-money-laundering","name":"https://therecord.media/lazarus-group-north-korea-tornado-cash-money-laundering","url":"https://therecord.media/lazarus-group-north-korea-tornado-cash-money-laundering"},{"archive_timestamp":"2026-01-28T13:50:47+00:00","archive_url":"http://web.archive.org/web/20260128135047/https://etherscan.io/address/0x12d66f87a04a9e220743712ce6d9bb1b5616b8fc","name":"https://etherscan.io/address/0x12d66f87a04a9e220743712ce6d9bb1b5616b8fc","url":"https://etherscan.io/address/0x12d66f87a04a9e220743712ce6d9bb1b5616b8fc"},{"archive_timestamp":null,"archive_url":null,"name":"https://etherscan.io/address/0x47CE0C6eD5B0Ce3d3A51fdb1C52DC66a7c3c2936","url":"https://etherscan.io/address/0x47CE0C6eD5B0Ce3d3A51fdb1C52DC66a7c3c2936"},{"archive_timestamp":null,"archive_url":null,"name":"https://etherscan.io/address/0x910cbd523d972eb0a6f4cae4618ad62622b39dbf","url":"https://etherscan.io/address/0x910cbd523d972eb0a6f4cae4618ad62622b39dbf"},{"archive_timestamp":"2026-04-08T08:45:54+00:00","archive_url":"http://web.archive.org/web/20260408084554/https://etherscan.io/address/0xa160cdab225685da1d56aa342ad8841c3b53f291","name":"https://etherscan.io/address/0xA160cdAB225685dA1d56aa342Ad8841c3b53f291","url":"https://etherscan.io/address/0xA160cdAB225685dA1d56aa342Ad8841c3b53f291"},{"archive_timestamp":"2026-05-24T02:20:58+00:00","archive_url":"http://web.archive.org/web/20260524022058/https://en.wikipedia.org/wiki/Tornado_Cash","name":"https://en.wikipedia.org/wiki/Tornado_Cash","url":"https://en.wikipedia.org/wiki/Tornado_Cash"}],"summary":"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.","timeline":[{"date":"2019-08-01","event":"Tornado Cash first fixed-denomination pool deployed on Ethereum mainnet.","source":"Tornado Cash — Wikipedia","source_url":"https://en.wikipedia.org/wiki/Tornado_Cash"},{"date":"2019-12-01","event":"Tornado Cash protocol formally launched by Roman Storm, Roman Semenov, and Alexey Pertsev.","source":"Tornado Cash Founders Charged — DOJ SDNY","source_url":"https://www.justice.gov/usao-sdny/pr/tornado-cash-founders-charged-money-laundering-and-sanctions-violations"},{"date":"2019-12-17","event":"Tornado Cash protocol deployed on Ethereum by Roman Storm, Roman Semenov, and Alexey Pertsev.","source":"Tornado Cash - Wikipedia","source_url":"https://en.wikipedia.org/wiki/Tornado_Cash"},{"date":"2020-01-01","event":"Core pool smart contracts made irreversibly immutable by developers, removing any individual ability to alter or control them.","source":"Fifth Circuit Opinion No. 23-50669","source_url":"https://www.ca5.uscourts.gov/opinions/pub/23/23-50669-CV0.pdf"},{"date":"2020-05-01","event":"Founding team relinquishes administrative control over the core protocol via Trusted Setup Ceremony, rendering primary smart contracts immutable.","source":"Tornado Cash - Wikipedia","source_url":"https://en.wikipedia.org/wiki/Tornado_Cash"},{"date":"2021-01-01","event":"TORN governance token launched, transferring protocol governance to the Tornado Cash community.","source":"Tornado Cash - Wikipedia","source_url":"https://en.wikipedia.org/wiki/Tornado_Cash"},{"date":"2022-03-23","event":"Lazarus Group hacks Axie Infinity's Ronin bridge, stealing approximately $625 million; over $455 million alleged to have been laundered through Tornado Cash.","source":"U.S. Treasury Sanctions Tornado Cash — Treasury.gov","source_url":"https://home.treasury.gov/news/press-releases/jy0916"},{"date":"2022-03-29","event":"Lazarus Group exploits Axie Infinity's Ronin Bridge for approximately $620 million; over $455 million subsequently laundered through Tornado Cash.","source":"U.S. Treasury Sanctions Notorious Virtual Currency Mixer Tornado Cash","source_url":"https://home.treasury.gov/news/press-releases/jy0916"},{"date":"2022-06-24","event":"Harmony Horizon Bridge heist: $96 million stolen, with funds alleged to have been laundered via Tornado Cash.","source":"U.S. Treasury Sanctions Tornado Cash — Treasury.gov","source_url":"https://home.treasury.gov/news/press-releases/jy0916"},{"date":"2022-08-02","event":"Nomad bridge hack: at least $7.8 million laundered through Tornado Cash.","source":"U.S. Treasury Sanctions Tornado Cash — Treasury.gov","source_url":"https://home.treasury.gov/news/press-releases/jy0916"},{"date":"2022-08-08","event":"OFAC designates Tornado Cash on the SDN List under IEEPA, citing over $7 billion in alleged laundering including Lazarus Group proceeds.","source":"U.S. Treasury Sanctions Notorious Virtual Currency Mixer Tornado Cash","source_url":"https://home.treasury.gov/news/press-releases/jy0916"},{"date":"2022-08-08","event":"OFAC designates Tornado Cash and adds 45 Ethereum addresses to the SDN list, citing over $7 billion in allegedly laundered virtual currency including Lazarus Group proceeds.","source":"OFAC Cyber-related Designation","source_url":"https://ofac.treasury.gov/recent-actions/20220808"},{"date":"2022-08-10","event":"Alexey Pertsev arrested in Amsterdam, Netherlands on suspicion of facilitating money laundering through Tornado Cash.","source":"Tornado Cash developer Alexey Pertsev convicted in The Netherlands - Axios","source_url":"https://www.axios.com/2024/05/14/tornado-cash-alexey-pertsev-crypto"},{"date":"2022-08-12","event":"Alexey Pertsev arrested by Dutch authorities in the Netherlands.","source":"Tornado Cash developer Alexey Pertsev convicted — Axios","source_url":"https://www.axios.com/2024/05/14/tornado-cash-alexey-pertsev-crypto"},{"date":"2022-09-08","event":"Van Loon v. Department of the Treasury filed in the Western District of Texas; plaintiffs backed by Coinbase challenge OFAC's authority to sanction immutable smart contracts.","source":"Crypto Engineers, Investors Sue US Treasury Over Tornado Cash Sanctions — CoinDesk","source_url":"https://www.coindesk.com/policy/2022/09/08/crypto-engineers-investors-sue-us-treasury-over-tornado-cash-sanctions"},{"date":"2022-11-01","event":"OFAC updates Tornado Cash designation to include 53 Ethereum addresses, among them at least 20 immutable smart contracts. Roman Semenov individually added to OFAC SDN List.","source":"Treasury Designates Roman Semenov — Treasury.gov","source_url":"https://home.treasury.gov/news/press-releases/jy1702"},{"date":"2022-11-01","event":"OFAC updates Tornado Cash designation to include 53 Ethereum addresses, adding immutable smart contracts to the SDN list.","source":"Tornado Cash Litigation Update - Lawfare","source_url":"https://www.lawfaremedia.org/article/tornado-cash-litigation-update"},{"date":"2022-11-01","event":"Tornado Cash users file suit in Van Loon v. Department of the Treasury, challenging OFAC's authority to sanction immutable smart contracts.","source":"Fifth Circuit Opinion - Van Loon v. Department of the Treasury","source_url":"https://www.ca5.uscourts.gov/opinions/pub/23/23-50669-CV0.pdf"},{"date":"2023-08-17","event":"Western District of Texas grants summary judgment in favor of Treasury in Van Loon case, upholding OFAC's designation of Tornado Cash.","source":"Coinbase-Funded Tornado Cash Lawsuit Against Treasury Department Ends In Defeat — CryptoNews","source_url":"https://cryptonews.com/news/coinbase-funded-tornado-cash-lawsuit-against-treasury-department-ends-in-defeat.htm"},{"date":"2023-08-23","event":"DOJ indicts Roman Storm and Roman Semenov in SDNY on three counts: conspiracy to commit money laundering, conspiracy to operate an unlicensed money transmitting business, and conspiracy to violate IEEPA sanctions. Storm arrested same day; Semenov remains at large.","source":"Tornado Cash Founders Charged With Money Laundering — DOJ SDNY","source_url":"https://www.justice.gov/usao-sdny/pr/tornado-cash-founders-charged-money-laundering-and-sanctions-violations"},{"date":"2023-08-23","event":"DOJ unseals indictment against Roman Storm and Roman Semenov on three counts: money laundering conspiracy, sanctions violations conspiracy, and operating an unlicensed money transmitting business. Roman Storm arrested in Washington State.","source":"IRS Criminal Investigation Media Release","source_url":"https://www.irs.gov/pub/irs-ci/j5-media-release-8-29-2023.pdf"},{"date":"2023-08-23","event":"OFAC separately designates Roman Semenov as a Specially Designated National. Semenov's location remains unknown.","source":"Treasury Designates Roman Semenov - U.S. Department of the Treasury","source_url":"https://home.treasury.gov/news/press-releases/jy1702"},{"date":"2023-09-06","event":"Roman Storm pleads not guilty in SDNY.","source":"Tornado Cash Developer Roman Storm Pleads Not Guilty — CoinDesk","source_url":"https://www.coindesk.com/policy/2023/09/06/tornado-cash-developer-roman-storm-pleads-not-guilty-to-money-laundering-other-charges"},{"date":"2024-05-14","event":"Dutch court in 's-Hertogenbosch finds Alexey Pertsev guilty of money laundering and sentences him to 64 months in prison.","source":"Tornado Cash developer Alexey Pertsev convicted — Axios","source_url":"https://www.axios.com/2024/05/14/tornado-cash-alexey-pertsev-crypto"},{"date":"2024-05-14","event":"Dutch court at 's-Hertogenbosch finds Alexey Pertsev guilty of money laundering and sentences him to 64 months (5 years and 4 months) in prison. Seized assets including a Porsche and €1.9 million in cryptocurrency are forfeited.","source":"Tornado Cash Developer Alexey Pertsev Found Guilty - CoinDesk","source_url":"https://www.coindesk.com/policy/2024/05/14/tornado-cash-developer-alexey-pertsev-found-guilty-of-money-laundering"},{"date":"2024-11-26","event":"Fifth Circuit reverses Western District of Texas ruling in Van Loon, holding that Tornado Cash's immutable smart contracts are not 'property' under IEEPA and OFAC exceeded its authority in designating them.","source":"Fifth Circuit Opinion No. 23-50669","source_url":"https://www.ca5.uscourts.gov/opinions/pub/23/23-50669-CV0.pdf"},{"date":"2025-02-07","event":"Dutch court grants Alexey Pertsev conditional release under electronic monitoring to prepare his appeal.","source":"Tornado Cash Developer Alexey Pertsev Released From Dutch Prison — The Daily Hodl","source_url":"https://dailyhodl.com/2025/02/07/tornado-cash-developer-alexey-pertsev-released-from-dutch-prison-as-he-appeals-five-year-sentence/"},{"date":"2025-03-21","event":"OFAC officially removes Tornado Cash from the SDN List. Roman Semenov remains individually sanctioned.","source":"OFAC Cyber-related Designation Removal — Treasury.gov","source_url":"https://ofac.treasury.gov/recent-actions/20250321"},{"date":"2025-03-21","event":"OFAC officially removes Tornado Cash and associated addresses from the SDN list, reversing the August 2022 designation.","source":"Tornado Cash Delisting - U.S. Department of the Treasury","source_url":"https://home.treasury.gov/news/press-releases/sb0057"},{"date":"2025-08-06","event":"Jury in SDNY convicts Roman Storm of conspiracy to operate an unlicensed money transmitting business; jury deadlocks on money laundering and sanctions violation counts.","source":"Tornado Cash Jury Deadlocked on Most Serious Charges — Money Laundering Watch","source_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/"},{"date":"2026-03-09","event":"DOJ files for retrial of Roman Storm on deadlocked counts, proposing October 2026 start date.","source":"US Government Seeking To Retry Tornado Cash Developer Roman Storm — The Daily Hodl","source_url":"https://dailyhodl.com/2026/03/11/us-government-seeking-to-retry-tornado-cash-developer-roman-storm-on-money-laundering-and-sanctions-violation-charges/"}]},"v":1}

   Verify offline (run on your own machine)

   python -m src.verify_decision 4446b6ac-128c-4207-8406-33b8275879bbcopy