Tornado Cash sanctions status (2022–2026)

OFAC sanctioned Tornado Cash smart-contract addresses in August 2022. The November 2024 Fifth Circuit ruling held that immutable code cannot be 'property' under IEEPA; OFAC partially walked back the listing in March 2025. Interaction by U.S. persons remains legally fraught.

What happened

• August 8, 2022: U.S. Treasury OFAC adds Tornado Cash contract addresses to the SDN list under IEEPA authority, prohibiting U.S. persons from interacting with them.
• September 2022: Civil suits filed challenging the sanction on First Amendment and APA grounds.
• August 2023: Roman Storm (Tornado Cash developer) is indicted on money-laundering and sanctions-evasion charges.
• August 2024: Roman Storm trial begins; outcome shapes operator-side risk for protocol developers.
• November 2024: Fifth Circuit (Van Loon v. Department of Treasury) rules that immutable smart contracts are not 'property' within the meaning of IEEPA — OFAC's sanction theory partially defeated on appeal.
• March 2025: OFAC removes the contract addresses from the SDN list (partial walk-back), retaining personal-name sanctions against individuals.

Why it matters

The Tornado Cash case is the defining 2020s legal test of whether decentralized code can be sanctioned the way property can. The Fifth Circuit ruling is the most significant pro-privacy crypto legal development in years. The case continues to shape how mixer and privacy-protocol developers think about liability.

Status in 2026

Contract addresses are no longer on the SDN list as of March 2025. Personal-name sanctions against specific individuals remain. Interacting with Tornado Cash contracts as a U.S. person remains legally fraught because of bank-secrecy-act and money-transmission concerns separate from OFAC, plus the ongoing prosecution of the developers. Treat as a case study, not a recommendation.

Related directory entries

• Tornado Cash seized · none kyc

Sources

1. U.S. Treasury — Tornado Cash sanctions announcement (August 2022)
2. Wikipedia — Tornado Cash
3. Van Loon v. Department of Treasury (Fifth Circuit, November 2024)

Explainer reviewed May 12, 2026. Cite as: https://fuckyc.org/explainers/tornado-cash-sanctions-status/