Court Upholds OFAC’s Designation of Tornado Cash Under IEEPA

The United States District Court for the Northern District of Florida issued a decision concerning the designation of Tornado Cash by the Office of Foreign Assets Control (OFAC). The case, identified as Case 3:22-cv-20375-TKW-ZCB, revolved around the designation of Tornado Cash under the International Emergency Economic Powers Act (IEEPA). The IEEPA authorizes the president to declare national emergencies to handle unusual foreign threats to the United States’ national security, foreign policy, or economy. Utilizing this authority, the president had declared national emergencies concerning malicious foreign cyber-enabled activities and North Korea’s nuclear missile program.

Tornado Cash, a service utilizing smart contracts on the Ethereum blockchain to provide a degree of anonymity to transactions, was designated by OFAC on August 8, 2022, and later re-designated on November 8, 2022. This designation was challenged by the plaintiffs, who are users and a non-profit cryptocurrency advocacy organization. They argued that the designation of Tornado Cash’s core software tool exceeded OFAC’s statutory authority since it is mere computer code and no foreign entity has a legally recognized “property interest.” The designation listed 91 internet addresses affiliated with Tornado Cash, aiming to block and prohibit transactions through these addresses.

The Court’s decision upheld OFAC’s designation. It rejected the plaintiffs’ argument, stating that the operative language in the IEEPA is “any interest,” not “property interest” or “ownership interest.” According to the Court, Tornado Cash’s founders, developers, and Decentralized Autonomous Organization (DAO) have an indirect beneficial “interest” through the service’s usage, which increases the value of Tornado Cash’s governance token, TORN. The Court explained that an increased usage of Tornado Cash enhances the value of TORN, held by these entities, and thus establishes a financial “interest” for the purposes of the IEEPA.

Furthermore, the Court found that OFAC’s decision was not arbitrary or capricious and was adequately justified based on the foreign-affairs rationale, particularly given Tornado Cash’s involvement in laundering cryptocurrency for the benefit of the North Korean government. The Court also dismissed the plaintiffs’ First Amendment claims, stating the designation didn’t implicate Plaintiffs’ First Amendment rights as there are other privacy tools available for them.

In conclusion, the Court denied the plaintiffs’ motion for summary judgment and granted the defendants’ cross-motion for summary judgment, thereby upholding OFAC’s designation of Tornado Cash under the IEEPA. This judgment underscores the legal challenges faced by privacy-centric blockchain services in light of national security and foreign policy concerns.

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FinCEN Issues Alert to Counter Financing to Hamas and its Terrorist Activities

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued an alert on October 20, 2023, aimed at assisting financial institutions in identifying funding streams that support the terrorist organization Hamas. This move comes after a devastating attack on Israel on October 7, 2023, orchestrated by Hamas, which resulted in significant casualties, including U.S. citizens.

Hamas employs a multifaceted approach to raise funds for its operations. According to the U.S. Department of the Treasury, the organization receives support from Iran, estimated at times to be as high as $300 million per year. Additionally, Hamas utilizes private donations, a global portfolio of investments, and diverts aid from legitimate charities. They also control border crossings and avenues of commerce, engage in racketeering, and run extortionary practices around local populations. Notably, Hamas has been involved in fundraising campaigns that use both fiat and virtual currencies.

FinCEN has outlined specific red flag indicators to help financial institutions detect, prevent, and report potential suspicious activity related to Hamas’s terrorist financing. These indicators include transactions with OFAC-designated entities, transactions indicating support for terrorist campaigns, and transactions involving high-risk jurisdictions tied to Hamas activity. Financial institutions are urged to include the key term “FIN-2023-TFHAMAS” in Suspicious Activity Reports (SAR) to indicate a connection with the alert.

As part of a whole-of-government response, the Treasury is engaging with foreign counterparts to deny Hamas the ability to raise and use funds worldwide. Numerous Hamas members and financial facilitators have been designated by the Office of Foreign Assets Control (OFAC) in various countries, including Sudan, Türkiye, Algeria, and Qatar.

FinCEN has also expressed concerns over the use of virtual currencies and online platforms in financing terrorist activities. The alert specifically mentions that Hamas has been involved in fundraising campaigns involving virtual currency and fictitious charities. Financial institutions are advised to be vigilant in monitoring transactions that involve virtual currencies, especially those that originate from or are directed to high-risk jurisdictions.

Given the evolving nature of terrorist financing methods, FinCEN is continuously updating its guidelines and working closely with international partners to curb the flow of funds to terrorist organizations. Financial institutions are advised to stay updated on FinCEN’s alerts and guidelines to ensure compliance and contribute to national security efforts.

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US Treasury Targets Hamas Financial Networks Post-Israel Attack

In a decisive response to the recent terrorist attack on Israel, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) designated ten individuals and entities linked to the Hamas terrorist organization. This action, aimed at crippling the financial structures supporting Hamas, encompasses individuals and operations not only in the Gaza Strip but extends to Sudan, Türkiye, Algeria, and Qatar.

Sanctions Detail

The sanctions zero in on various facets of Hamas’s financial network. Among those designated are individuals managing a clandestine Hamas investment portfolio, a Qatar-based facilitator with close Iranian affiliations, a senior Hamas commander, and a Gaza-based virtual currency exchange along with its operator. These sanctions build on previous actions dating back to May 2022, targeting officials and companies entangled in Hamas’s concealed global investment portfolio. The current designations are emblematic of a broader US strategy to dismantle the revenue streams fueling Hamas’s activities in the West Bank, Gaza, and beyond, closely coordinated with regional allies.

Hamas’s global financial operations, veiled as legitimate businesses, have purportedly amassed revenue in hundreds of millions, with investments spanning several countries including Sudan, Algeria, Türkiye, and the United Arab Emirates. The United States seeks to expose and freeze these assets to curtail Hamas’s ability to finance its operations.

Key Individuals and Entities

Highlighted among those sanctioned are Musa Muhammad Salim Dudin, a West Bank-based Hamas official, and Abdelbasit Hamza Elhassan Mohamed Khair, a Sudan-based financier who managed several companies within Hamas’s investment portfolio. In Türkiye and Algeria, Amer Kamal Sharif Alshawa, Ahmed Sadu Jahleb, Aiman Ahmad Al-Duwaik, and Walid Mohammed Mustafa Jadallah were identified as part of Hamas’s investment network, with various roles in supporting the terrorist organization’s financial infrastructure.

Muhammad Ahmad ‘Abd Al-Dayim Nasrallah and Ayman Nofal, based in Qatar and Gaza respectively, were also designated for their significant roles within Hamas. The actions further extended to Buy Cash Money and Money Transfer Company, a Gaza-based virtual currency exchange, and its owner Ahmed M. M. Alaqad, for their material support to Hamas.

Virtual Currency Concerns

OFAC’s action underscores the evolving challenge posed by virtual currencies in financing terrorism. The seizure of virtual currency wallets linked to Hamas in 2021 by Israel’s National Bureau for Counter Terrorist Financing serves as a precursor to the concerns echoed in these sanctions. The designation of Buy Cash, involved in virtual currency transactions including Bitcoin, highlights a nuanced dimension of terror financing that demands international attention and action.

Sanctions Implications

The ramifications of these sanctions are extensive. They mandate the freezing of all property and interests in the US or under US persons’ control belonging to the designated individuals and entities. Additionally, they underscore the risks financial institutions and other entities might face if found engaging in transactions with the designated persons, thereby reinforcing the robustness and the dynamic enforcement landscape of the US sanctions regime.

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Ethereum is Getting Closed to Being Completely Censored Because of OFAC Regulations

The percentage of OFAC-compliant Ethereum blocks being created every day has increased to 73%, which heightens censorship worries in the blockchain ecosystem.


Following Ethereum framework censorship that posits barriers to the crypto ecosystem’s goal of extremely open and accessible finance, the market has been monitoring Ethereum’s increasing adherence to guidelines set forth by OFAC. As per the development, over 73% of the blocks on the Ethereum network in the past 24 hours have been determined to enforce OFAC compliance.

Following the discovery that 51% of-Ethereum-blocks met OFAC requirements back in October 2022, top crypto media firms published an article on the growing censorship issues. But according to mevWatch data, as of November third, daily block production that complies with OFAC regulations has increased to 73%.

Meanwhile, some OFAC-mandated MEV-Boost relays would censor financial activities. Consequently, to guarantee Ethereum’s neutrality, a non-censoring MEV-Boost relay must be implemented by the network.

Additionally, by removing relays like BloXroute Max Profit, BloxRoute Ethical, Manifold, and Relayooor from their MEV-Boost configuration, Ethereum examiners can lessen their adherence to OFAC regulations.

US Government Agency Enforces Sanctions on Crypto Outlets

Based on the adherence to OFAC, the United States Government agency can apply economic and trade sanctions on crypto outlets. Meanwhile, Tornado Cash and several Ethereum addresses had already been sanctioned by the agency. Furthermore, as of the time of writing this report, 45% of all Ethereum blocks are in full adherence to the OFAC regulations. 

Following the launch of crypto exchanges by UnionBank, one of the biggest multinational banking institutions in the Philippines, in collaboration with the Swiss crypto company Metaco, the adoption of Bitcoin BTC tickers fell by $21,265 while Ethereum accelerated.

This suggests that despite the alleged censorship of the protocol, it is still widely used today.

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US Treasury Fines Bittrex Exchange $29m for Multi-Year Sanctions Violation

Washington-based cryptocurrency trading platform, Bittrex Has been fined the sum of $29 million by the United States Treasury Department through the Office of Foreign Assets Control (OFAC) and the Financial Crimes Enforcement Network (FinCEN). 


The fone, tagged as the single largest levied by the OFAC on a digital currency trading platform, became necessary, considering Bittrex failed to implement adequate compliance programs, thus helping some of its users to evade established sanctions. 

According to the OFAC announcement, the trading platform “failed to prevent persons apparently located in the Crimea region of Ukraine, Cuba, Iran, Sudan, and Syria from using its platform to engage in approximately $263,451,600.13 worth of virtual currency-related transactions between March 2014 and December 2017.”

The regulator noted that preventing these banned users would have been easy if the exchange prevented their registration based on their IP addresses at the point of registration. The FinCEN violation involved failure on the part of the trading platform to institute appropriate Anti-Money Laundering (AML) measures, thus creating a weak channel for the laundering of illicit financial proceeds.

“When virtual currency firms fail to implement effective sanctions compliance controls, including screening customers located in sanctioned jurisdictions, they can become a vehicle for illicit actors that threaten U.S national security,” said OFAC Director Andrea Gacki. “Virtual currency exchanges operating worldwide should understand both who—and where—their customers are. OFAC will continue to hold accountable firms, in the virtual currency industry and elsewhere, whose failure to implement appropriate controls leads to sanctions violations.”

The US Treasury has been more alive towards cryptocurrency service providers all year long, first coming into the limelight in May when it banned crypto mixer, and subsequently when it added Tornado Cash to its list. 

While the industry made no fuss about the Blender ban, that of Tornado Cash has been received with so many objections, all of which have spurred industry giants like Coinbase Global Inc to fund targeted lawsuits and advocacy stunts.

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Tether Says Will Not Block Tornado Cash until it is Directed by Authorities

The broader cryptocurrency industry is subtly pushing back against the sanctions on Tornado Cash by the United States Treasury Department for facilitating the transaction of illicit funds.


In a new report by the Washington Post, USDT issuer, Tether has affirmed it will not be blockchain addresses linked to Tornado Cash unless explicitly asked to do so by the government.

Prior to seeking confirmation from Tether’s CTO Paolo Ardoino about its stance on blocking addresses linked to Tornado Cash, The Washington Post’s report was based on Dune Analytics data which shows Tether Holdings has not taken any actions against these wallet addresses.

“Tether has not been contacted by U.S. officials or law enforcement with a request” to freeze transactions with Tornado Cash, Ardoino said in a statement, adding that the company “normally complies with requests from U.S. authorities.”

Industry experts believe Tether may be in violation of the broader Office of Foreign Assets Control’s (OFAC) sanctions. While the embargo on Tornado Cash actually prohibits U.S. businesses or individuals from transacting using the crypto mixer, non-US companies that do business with Americans are also indirectly banned from aiding the operations of the smart contract-controlled platform.

The ban, in general, has been viewed through different lenses, one of which pushed Congressman Rep Tom Emmer to inquire from Treasury Secretary Janet Yellen why a piece of technology that cannot defend itself was sanctioned. 

While many industry analysts see defiance, Ardoino said the company, known for crossing paths with regulators over the shares on regulatory affairs, is in constant touch with the regulators and often complies with their requests.

“We have been cooperating on various freezes with U.S. law enforcement, including in the last two weeks after the OFAC public disclosure about Tornado Cash, and no specific request has been put to us related to freezing relevant Tornado Cash addresses,” he said.

It is yet to be seen whether OFAC will make the private request to halt transactions originating from Tornado Cash. Still, from current events, more clarity may be given on how private companies are required to cooperate with the sanctions.

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Lazarus-Linked Added to US Treasury’s Sanction List

Bitcoin and cryptocurrency mixing service, has been added to the sanctions list by the United States Treasury Department. 


The startup which helps facilitate private cryptocurrency transactions was added to the list as investigations showed that it was used by the North Korea-based hacking group, Lazarus who stole $620 million from the Ronin Network.

As detailed by the US Treasury Department, the hackers have used to conceal and launder as much as $20.5 million of the illicit proceeds. The Treasury Department believes that the pressure from the United Nations as well as the United States has turned North Korea to start exploring other avenues to fund its nuclear program, and the activities of the Lazarus Group are one manifestation.

“Today, for the first time ever, Treasury is sanctioning a virtual currency mixer,” said Under Secretary of the Treasury for Terrorism and Financial Intelligence Brian E. Nelson. “Virtual currency mixers that assist illicit transactions pose a threat to U.S. national security interests. We are taking action against illicit financial activity by the DPRK and will not allow state-sponsored thievery and its money-laundering enablers to go unanswered.”

The exploit of Axie Infinity’s Ronin Bridge was considered the biggest hack in the decentralized finance world to date and concerted efforts have been deployed by all relevant stakeholders to help the blockchain protocol recover the funds. While Binance recently helped in retrieving $5.8 million which was laundered through the platform, the activities of services like come off like a freedom pass for the cybercriminals.

Besides being the go-to platform for the Lazarus Group, the Treasury Department also believes Blender is a viable tool being adopted by other cybercrime rings including Trickbot, Conti, Ryuk, Sodinokibi, and Gandcrab, all connected to Russia.

With the sanctions in place, all of the platform’s properties must be reported to the Office of Foreign Assets Control (OFAC) and among many other restrictions, Americans are banned from doing business with the startup.

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U.S. Office of Foreign Assets Control Releases Guidance for Crypto Space

The U.S. Treasury Department is releasing new sanction guidelines for the cryptocurrency industry.

The Department’s Office of Foreign Assets Control (OFAC) recently published new instructions for crypto businesses and investors, saying that individual investors should expect to be scrutinized in terms of who they can and can’t deal with, just like traditional financial institutions.



“The growing prevalence of virtual currency as a payment method… brings greater exposure to sanctions risks. Accordingly, the virtual currency industry, including technology companies, exchangers, administrators, miners, wallet providers, and users, plays an increasingly critical role in preventing sanctioned persons from exploiting virtual currencies to evade sanctions and undermine US foreign policy and national security interests.

The brochure states that everyone engaged in crypto-related activities must be vigilant regarding who they transact with in order to avoid violating sanctions rules.

“OFAC is issuing this guidance to assist the virtual currency industry in mitigating these risks. OFAC sanctions compliance obligations apply equally to transactions involving virtual currencies and those involving traditional fiat currencies.

Members of the virtual currency industry are responsible for ensuring that they do not engage, directly or indirectly, in transactions prohibited by OFAC sanctions, such as dealings with blocked persons or property, or engaging in prohibited trade- or investment-related transactions.”

OFAC currently has 35 different sanctions in place, the most common being limitations on dealings with foreign governments, entire countries or geographic locations, and specifically listed individuals. According to the guidelines, OFAC has the authority to impose “substantial” civil penalties for noncompliance.

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Binance Plays Role in U.S. Sanctions Against Russian Crypto Exchange

Key Takeaways

  • Binance has revealed its collaboration with law enforcement agencies on an investigation against Suex.
  • Suex is a Russian crypto exchange has been sanctioned by U.S. for laundering assets connected with ransomware attacks.
  • Suex’s illicit activities appeared on Binance’s radar after an in-house investigation on internal safeguards.

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Leading crypto exchange Binance has aided the OFAC’s investigation into the Russian crypto exchange Suex OTC.

Binance Reports Ransomware-Linked Money Laundering

One of the top global crypto exchanges, Binance, revealed it has collaborated with law enforcement agencies on sanctions taken against Suex, a Russian crypto exchange that allegedly laundered money for cybercriminals.

On Wednesday, the U.S. Treasury’s Office of Foreign Assets Control (OFAC) announced a set of actions to be taken against crypto addresses belonging to Suex–a Russian exchange found laundering assets connected with ransomware attacks.

In a blog post, Binance detailed its collaboration with law enforcement agencies. Speaking on the matter, the exchange said:

“Based on a comprehensive audit by our investigative team, several accounts related to the addresses mentioned in the OFAC announcement were identified earlier this year and had appropriate action taken against them.”

Ransomware attacks have become a major concern for various government institutions worldwide, costing over $400 million in 2020, four times the levels in 2019. Various experts in the U.S. and across the globe have called ransomware a national security threat.

According to Binance, Suex’s illicit activities appeared on its radar after an internal audit of the exchange’s records. After this, Binance shared its findings against Suex with U.S. law enforcement agencies.

Months before OFAC sanctions against Suex were made, Binance had already banned crypto addresses from the Russian exchange. The decision was made due to internal safeguards against money laundering. Binance also shared its findings with the appropriate authorities, the exchange said.

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It is worth noting that despite Binance’s recent collaboration with authorities, the exchange itself has previously faced several regulatory issues.

In 2021, regulators from the U.K., Japan, Italy, Malaysia, Singapore and others countries warned the exchange about offering services to their citizens without proper registration and KYC verification. However, Changpeng “CZ” Zhao, the exchange’s CEO, has since promised a transition to a state of proactive compliance.

The Binance CEO has also stated plans to shift Binance to a centralized headquarters and quit its current decentralized operations for compliance needs. The exchange has even hired investigators and ex-officers from top agencies to help the platform comply with financial laws.

To meet this regulatory compliance goal, the firm has implemented full KYC norms for all traders on its platform. However, before the rule, Binance had been offering services to unverified users for some years, potentially allowing the platform to be used for nefarious activities. Due to this, Binance was also reportedly investigated by U.S. agencies for violations of AML regulations.

Binance’s recent cooperation with U.S. authorities and improvement of its KYC and AML procedures may help the exchange to reduce the troubles it has faced with regulators.

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Treasury Sanctions Crypto Exchange Over Ransomware Payments

Key Takeaways

  • The U.S. Treasury’s Office of Foreign Assets Control has sanctioned the Russian crypto broker Suex.
  • According to OFAC, Suex was laundering illegal proceeds for ransomware actors, scammers, and darknet market operators.
  • Statements from U.S. officials indicate that more sanctions of a similar nature should be expected.

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The U.S. Treasury’s Office of Foreign Assets Control has imposed sanctions on the Russia-based cryptocurrency broker Suex for allegedly helping launder ransomware payments. Americans are now forbidden from using the company’s services.  

OFAC Blacklists Russian Suex

The U.S. Treasury has blacklisted the Russian OTC crypto broker Suex for allegedly laundering ransomware payments.

Targeting and placing Suax on OFAC’s blacklist marks the first time the U.S. has sanctioned a cryptocurrency exchange platform. According to the Treasury’s Tuesday announcement, Suex, whose physical offices are located in Moscow and St. Petersburg, facilitated payments for ransomware actors, scammers, and darknet market operators. 

OFAC’s updated advisory document reads:

“In Sep. 2021, OFAC designated SUEX OTC, S.R.O. (“SUEX”), a virtual currency exchange, for its part in facilitating financial transactions for ransomware actors, involving illicit proceeds from at least eight ransomware variants. Analysis of known SUEX transactions showed that over 40% of SUEX’s known transaction history was associated with illicit actors.”

Blockchain analytics firm Chainanalysis, which helped OFAC’s investigation of Suex, revealed today that it had been tracking the broker’s money laundering activity for a while. Chainanalysis found that Suex had processed hundreds of millions of dollars worth of cryptocurrency over the last three years, much of which allegedly came from illicit and high-risk sources.

According to Chainanalysis’ report, Suex laundered over $160 million in Bitcoin alone, converting the illicit proceeds into cash at physical branches in Moscow, St. Petersburg, and possibly other offices outside of Russia. Over $50 million worth of Bitcoin allegedly came from the illicit BTC-e crypto exchange the U.S. authorities shut down years ago.

“Today’s action is a signal of our intention to expose and disrupt the illicit infrastructure using these attacks,” Deputy Treasury Secretary Wally Adeyemo told reporters ahead of the announcement. 

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Following this year’s Colonial Pipeline incident, America is decidedly setting its sights on cryptocurrency ransomware attacks, meaning more sanctions on crypto platforms aiding these activities should be expected. Expounding on OFAC’s recent action in a Tuesday statement, Treasury Secretary Jenet Yallen said:

“Ransomware and cyber attacks are victimizing businesses large and small across America and are a direct threat to our economy. We will continue to crack down on malicious actors. As cyber criminals use increasingly sophisticated methods and technology, we are committed to using the full range of measures, to include sanctions and regulatory tools, to disrupt, deter, and prevent ransomware attacks.”

OFAC administers and enforces sanctions based on U.S. foreign policy and national security goals against targeted foreign countries or individuals, including terrorists, international narcotics traffickers, and money launderers. When OFAC “blacklists” or puts someone on the Specially Designated Nationals and Blocked Persons List (SDN), it means that their assets are blocked, and U.S. citizens are prohibited from dealing with them.

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