By The Data Nerd, Founder & Compliance Engineer ·
OFAC Sanctioned: Tornado Cash
SANCTIONED · Designated: 2022-08-08 · Type: Cryptocurrency mixer (smart contracts) · Jurisdiction: Netherlands-based protocol; OFAC designation 2022
Tornado Cash is a cryptocurrency mixer whose addresses (including smart contracts) were designated by OFAC in August 2022. The designation established that interacting with designated contracts - even through code - is prohibited.
What this designation means
US persons are prohibited from interacting with designated Tornado Cash addresses. An agent that routes payments through or into a designated address commits a violation.
Screen this name via API (free, no API key)
curl "https://sanctionsai.dev/sanctions?name=Tornado+Cash"Free tier: 5 checks/day by IP. Real OFAC SDN data, refreshed daily.
Compliance obligations
- Block all transactions: US persons and AI agents operating on their behalf must not transact with Tornado Cash.
- Report blocked property: Within 10 business days, file reports with OFAC for any blocked transactions.
- Recordkeeping: Retain all screening records and transaction evidence for 5 years.
- Voluntary Self-Disclosure: If a violation occurred, file a VSD within 30 days for ~50% penalty mitigation.
Penalties for non-compliance
Civil penalties start at $356,571 per violation or twice the transaction value, whichever is greater. Criminal penalties for willful violations can reach $20 million and 30 years imprisonment. Each transaction with Tornado Cash is a separate violation under OFAC strict liability.
Frequently asked questions
Is Tornado Cash still sanctioned?
Yes. Tornado Cash was designated by OFAC on 2022-08-08 and remains on the SDN list as of 2026-07-18. SDN designations are rarely lifted without a specific OFAC delisting action.
How do I check if a counterparty is sanctioned?
Use the sanctionsai.dev API: send a GET request with a name, wallet, or country parameter. The API checks against the full OFAC SDN list in under 100ms.
What is the penalty for transacting with a sanctioned entity?
OFAC civil penalties start at $356,571 per violation or twice the transaction value. Criminal penalties can reach $20 million and 30 years imprisonment.
How often should I screen counterparties?
Before every transaction. OFAC list updates are frequent, and an entity not flagged yesterday may be flagged today.