22 September 2026 · Mixers, tumblers and privacy coins
The sanction that was lifted
In August 2022 the US Treasury designated Tornado Cash, a cryptocurrency mixer, citing more than $7bn laundered through it since 2019 including proceeds of the Ronin Bridge theft attributed to the DPRK-linked Lazarus Group.
In November 2024 the Fifth Circuit held that the mixer's immutable smart contracts are not property capable of being blocked under the International Emergency Economic Powers Act. They have no owner, no controller and nobody who can be excluded from them. On 21 March 2025 OFAC delisted it, and a Texas court later enjoined enforcement of the designation.
The mechanism did not change. What changed is whether the tool itself can be sanctioned.
The pattern
This is the mixers and privacy-assets typology: funds are pooled and redistributed, or swapped into an asset whose ledger does not expose amounts or counterparties, breaking deterministic tracing. For a bank the exposure almost always arrives already laundered, at the off-ramp.
A designation is lifted from a mixing service. What changes for a bank's controls?
One tap. The answer appears straight away.