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EMBARGOED!: Blowing in the Wind: The Tornado Cash Designation, Mixers, and Federal Litigation


On this episode of EMBARGOED!, host Tim O'Toole and guest Leah Moushey (Counsel, Miller & Chevalier) return to the subject of cryptocurrency mixers, specifically in the context of Tornado Cash and recent agency guidance.  Their discussion looks at the recent federal ruling in a challenge to its designation brought by Tornado Cash and the subject of cryptocurrency and Office of Foreign Assets Control (OFAC) designations generally.


  • Introduction
  • Tornado Cash
    • OFAC Designation
    • Storm and Semenov charged with conspiracy to commit sanctions violations
  • FinCEN proposes new regulation to enhance transparency in convertible virtual currency mixing and combat terrorist financing
  • Hamas virtual currency fundraising and sanctions


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EMBARGOED! is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.

EMBARGOED! is intelligent talk about sanctions, export controls, and all things international trade for trade nerds and normal human beings alike. Each episode will feature deep thoughts and hot takes about the latest headline-grabbing developments in this area of the law, as well as some below-the-radar items to keep an eye on. Subscribe wherever you get your podcasts for new bi-weekly episodes so you don't miss out!