2022 Trust Forum Presentations

INTERNAL FR/OFFICIAL USE // SECURE EXTERNAL

Recent Enforcement Actions

11/3/2022

11

INTERNAL FR/OFFICIAL USE // SECURE EXTERNAL

Tornado Cash

• In August, OFAC sanctioned virtual currency mixer Tornado Cash, pursuant to Executive Order 13694 o Tornado Cash is a Ethereum blockchain based that automatically executes transactions without intervention from any middleman or third party • Tornado Cash is: o Decentralized – dissociated from control of any particular entity or individual o Noncustodial and o Open-source • Lawsuit against OFAC for sanctioning an algorithm/smart contract filed by six Tornado Cash users, backed by cryptocurrency exchange Coinbase o Did OFAC exceed its authority in sanctioning Tornado Cash?

11/3/2022

12