On August 8, 2022, OFAC sanctioned the Tornado.Cash protocol, which was used by the North Korea hackers to launder stolen funds.

Adding a protocol to the Specially Designated Nationals (SDN) list is a new and slippery slope.  Historically, the SDN list is composed of individuals or businesses that are cut-off from the American economy because they are suspected to be terrorists or drug king pins. By treating autonomous code as a “person” OFAC may have exceeded its statutory authority.