Treasury removes Tornado Cash property and addresses from OFAC sanctions lists

What changed

Treasury removed Tornado Cash-related persons and property from OFAC’s Specially Designated Nationals and Blocked Persons List following legal and policy review. Delisting removes those particular blocking sanctions but does not eliminate sanctions screening, anti-money-laundering duties, or exposure to independently sanctioned counterparties.

Who it affects

• Advisers and compliance teams screening wallets and protocols
• Custodians, exchanges, transaction-monitoring providers, and clients

What is still open

• How providers will update risk models and service restrictions
• Ongoing litigation and treatment of transactions involving separately sanctioned actors

What it means for an advisor

• Update sanctions-screening references and vendor rules to reflect the official delisting
• Do not equate delisting with a general finding that all Tornado Cash-related activity is lawful or appropriate

Previous interpretation

OFAC designations required U.S. persons to block covered Tornado Cash property and avoid prohibited dealings absent authorization.