OFAC FAQ (Current) # 1095 - Cyber-related Sanctions

Date issued: Nov. 08 2022

Last substantive commentary amendment:
Aug. 19 2023

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TURBOFAC Commentary (134 words)

Notes:

1) Read in conjunction with Treasury Designates DPRK Weapons Representatives (November 8, 2022 Press Release) and Consolidated Comment on the Designation and Redesignation of Tornado Cash; Ensuing Litigation (System Ed. Note).

This FAQ was issued concurrently with OFAC’s redesignation of Tornado Cash (as a reaction to a lawsuit challenging the designation in part based on an argument that “Tornado Cash,” as a software program, was not a “person” capable of designation. With the redesignation and this FAQ, OFAC appears to attempt to make clear that it does not regard the Tornado Cash software or computer code to be a “person” capable of blocking, but instead the “organization” associated with Tornado Cash. See FAQ # 1076, FAQ # 1077, FAQ # 1078, and FAQ # 1079 for further discussion on what the designation means...