Agent payment routed through a sanctioned mixer

What happens when an agent routes a payment through a sanctioned mixer, the strict-liability risk, and the control.

TL;DR

TL;DR: Routing funds through a designated mixer such as Tornado Cash or Blender.io is a transaction with a blocked party under strict liability. Screen the mixer address before routing and BLOCK flagged matches.

What happens

An agent is instructed to send value to a counterparty and, to preserve privacy or reduce cost, routes the payment through a mixing service. If that mixer is designated, the routing itself is the violation, because the agent transacts with the mixer even if the final recipient is legitimate. The mixing hop does not hide the transaction from sanctions rules; it creates a new one.

The risk

Mixers such as Blender.io and Tornado Cash sit on the SDN List. OFAC enforces under strict liability, so intent is not required, and civil penalties start at $356,000 per violation. The 50 Percent Rule extends the block to entities 50% or more owned by a blocked person, and successor mixers such as Sinbad.io inherit the designation.

The control

Screen every hop, not just the final recipient. agentmail checks a mixer address against 947 OFAC-listed crypto wallets in one call under 100 ms and returns BLOCK for a designated service before funds move. A clean counterparty returns ALLOW. The SCREEN, SCORE, STOP, STAMP protocol halts a flagged hop at the STOP gate, and dispute_open documents any unclear match instead of letting the agent route around it.