Tornado Cash is no longer on the US sanctions list. Treasury removed it on 21 March 2025, after a federal appeals court ruled in November 2024 that its immutable smart contracts could not be blocked as property. But a sanctions flag and a risk flag are different things, so an AML check can still mark coins that passed through Tornado Cash as risky.
2022: the designation
On 8 August 2022 OFAC, the US Treasury's sanctions office, sanctioned Tornado Cash. Treasury called it a virtual currency mixer and said it had been used to launder more than $7 billion since its creation in 2019. That included over $455 million stolen by the Lazarus Group.[1]
A mixer exists to make funds hard to trace: AMLBot describes mixed coins as coins that passed through a mixer "to make tracking difficult or impossible".[2] After the designation, Tornado Cash addresses sat on the SDN list, so US persons had to treat them like any other sanctioned party. OFAC's guidance says sanctions obligations are the same whether a transaction is in digital currency or fiat.[3]
2024: the Fifth Circuit ruling
The sanctions were challenged in court. In Van Loon v. Department of the Treasury, the US Court of Appeals for the Fifth Circuit ruled on 26 November 2024. In the court's words, "the immutable smart contracts at issue in this appeal are not property because they are not capable of being owned."[4]
The sanctions law lets OFAC block property, so contracts that are not property could not be blocked that way. The court reversed the lower court and sent the case back.[4]
2025: Treasury removes the sanctions
On 21 March 2025 Treasury announced: "we have exercised our discretion to remove the economic sanctions against Tornado Cash."[5] It said this followed its review of the novel legal and policy issues raised by using sanctions against activity in evolving technology environments. It also said it remains deeply concerned about North Korean hacking and laundering.[5]
Treasury's notice does not give the court ruling as the reason. Keep that in mind when you read summaries that link the two directly.
Timeline
| Date | Event | Source |
|---|---|---|
| 8 Aug 2022 | OFAC sanctions Tornado Cash | Treasury[1] |
| 26 Nov 2024 | Fifth Circuit: immutable contracts are not property | Court opinion[4] |
| 21 Mar 2025 | Treasury removes the sanctions | Treasury[5] |
What changed for AML checks
The sanctions match is gone. A check against today's SDN list should no longer return Tornado Cash as a sanctioned entity. You can confirm any address yourself in OFAC's free Sanctions List Search: enter the full address in the "ID #" field. It returns exact matches only, so paste carefully.[6]
The mixer flag is not gone. AML services do not only look for sanctions. AMLBot, for example, lists "Sanctions" and "Mixer" as separate categories under its Danger heading. The mixer category is about how coins moved, not about who is sanctioned.[2] Removing a sanction does not change it. A provider can still score Tornado Cash exposure as high risk, and exchanges may still treat mixer history as a reason for review.
Old reports may be out of date. A report made before 21 March 2025 may show Tornado Cash addresses as sanctioned.[5] So can a provider that has not updated its labels. Look at the date of any report you are shown, and ask the provider to rerun it if it is old.
Other sanctions still apply. The delisting was about Tornado Cash. Other parties keep their own SDN entries. For example, OFAC added an Ethereum address to the Lazarus Group's entry in April 2022.[7] OFAC also says the addresses it lists may not be exhaustive.[3] Funds linked to a sanctioned party can still be a problem, whatever route they took.
We do not give legal advice. If you are a business with US sanctions obligations, or a person whose funds are held over past Tornado Cash use, talk to a lawyer in your country.
Why a report still says "high risk"
Here is how it can look. You withdraw ETH to an exchange, and the exchange holds the deposit. Its screening tool sees that some of the coins, several hops back, came out of Tornado Cash. That is mixer exposure. The tool may score it high whether or not the mixer is sanctioned today. The delisting gives you a fact to point to. It does not erase the history.
What to do
- Check the report date. Anything from before 21 March 2025 may still call Tornado Cash sanctioned.
- Run the address through OFAC's search using the "ID #" field.[6]
- Read the category, not just the score. "Sanctions" and "Mixer" are separate flags. Know which one you are dealing with.
- Keep records of where your coins came from, in case an exchange asks.
- Answer an exchange review through official support only. See our guide on what to do if an exchange froze your crypto.
To understand how providers turn exposure into a number, read what an AML risk score means.
General information, not legal or financial advice. Rules differ by country and change; check the linked sources.
Sources
- U.S. Department of the Treasury — U.S. Treasury Sanctions Notorious Virtual Currency Mixer Tornado Cash (jy0916) (8 Aug 2022). Checked 4 Nov 2026.
- AMLBot — What do we analyze?. Checked 4 Nov 2026.
- U.S. Treasury, Office of Foreign Assets Control — OFAC FAQs: Questions on Virtual Currency (19 Mar 2018). Checked 4 Nov 2026.
- U.S. Court of Appeals for the Fifth Circuit — Van Loon v. Department of the Treasury, No. 23-50669 (26 Nov 2024). Checked 4 Nov 2026.
- U.S. Department of the Treasury — Tornado Cash Delisting (sb0057) (21 Mar 2025). Checked 4 Nov 2026.
- U.S. Treasury, Office of Foreign Assets Control — OFAC FAQ 594. Checked 4 Nov 2026.
- U.S. Treasury, Office of Foreign Assets Control — Cyber-related Designation Update (14 Apr 2022). Checked 4 Nov 2026.