On 15 September, Dinsmore & Shohl LLP published an article about OFAC providing guidance in the form of updated FAQ relating to the sanctions against Tornado Cash, the Ethereum “mixer” it blacklisted in August, following allegations that North Korea used Tornado Cash to launder stolen digital assets.  It explains that the information provides guidance on 4 points: the ability to withdraw funds from wallets associated with the Tornado Cash blacklist; whether the OFAC reporting obligations apply to “dusting” transactions; whether U.S. persons can engage in transactions involving addresses implicated in the blacklist without a license; and what, more generally, is prohibited in the wake of the OFAC blacklisting of Tornado Cash.


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Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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