OFAC FAQ (Current) # 1077 - Cyber-related Sanctions

Date issued: Sep. 13 2022

Last substantive commentary amendment:
Aug. 19 2023

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TURBOFAC Commentary (199 words)

Notes:

[11-29-24 Update - see Joseph Van Loon et al v. Department of the Treasury et al. (2024, 5th Cir.), and comments thereto. This FAQ is likely to be removed or amended at some point in the future; the below has not yet been amended in light of the 5th Circuit opinion.]

1) On 9-13-22 OFAC issued four Tornado Cash-related FAQs (FAQ # 1076, FAQ # 1077, FAQ # 1078, FAQ # 1079). Read this FAQ in conjunction with the others.

2) Note that, based on OFAC rationale for blocking Tornado Cash (see Tornado Cash System Note), it is not the case that only the wallet addresses identified would be subject to sanctions.

3) As discussed at section 2(b) of...