RIADeFi
Not approved · Other

Ketju memo: Tornado Cash

Not approvedPublished by Ketju Research

This memo sets out what the holder owns, who controls it, how holders could lose money, and whether a position can be sold. The advisor decides any client action and amount. Not investment, legal, tax, or compliance advice.

Summary

Ketju does not approve Tornado Cash: it is privacy infrastructure, and its anti-money-laundering, source-of-funds, note-custody and counterparty-screening demands put it outside the types Ketju approves. It pays no yield, so yield plays no part in the verdict. Treasury removed its sanctions on Tornado Cash in March 2025, and the verdict does not rest on them. In 2025, DOJ obtained a conviction for knowingly operating an unlicensed money-transmitting business that moved criminal proceeds. The immutable pools cannot screen counterparties.

Review triggers

  • Counsel and compliance approve a privacy mandate for one client with a documented lawful purpose and controls to monitor transactions
  • The custodian, bank and tax-reporting counterparties confirm in writing that they accept the proposed flow and compliance report
  • A test at the proposed size keeps the withdrawal note safe and produces a complete source-of-funds report without an unapproved relayer

Facts

Verdict
Not approved
Type
Other
Chains examined
Ethereum, BSC, Arbitrum, Gnosis, Polygon, Avalanche, OP Mainnet, Ethereum Classic
Reviewed
Last confirmed

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