OverviewIn March 2025, the Treasury Department’s Office of Foreign Assets Control (OFAC) delisted the Tornado Cash smart contracts from its Specially Designated Nationals (SDN) list. The announcement came after the Fifth Circuit Court of Appeals ruling in Van Loon v. Department of Treasury that Tornado Cash smart contracts are not property or interests in property under the International Economic Emergency Protections Act (IEEPA) and that OFAC had overstepped its regulatory authority in is...