You believe that it is illegal to merely accept money from someone you believe to be a sanctions violator? Could you expand on that theory?

It is not illegal to sell a house to a known drug dealer, and neither is it illegal to accept a donation from a drug dealer. Why do you think this situation would be different?

What you're saying is that, as the address the developer received the money from was not specifically listed by OFAC as Tornado Cash (in [1]), it wouldn't be a prohibited transaction for the developer that would need reporting, even though it seems like it was just transferred from 0xA160cdAB225685dA1d56aa342Ad8841c3b53f291 (on the SDN list from OFAC) a few minutes before through a few addresses? I don't really know, but if that were the case, that seems like it would enormously limit the applicability of the sanctions?

[1] https://sanctionssearch.ofac.treas.gov/Details.aspx?id=38499

What's the alternative? Sanctions don't permanently taint money.

If it's interpreted as accepting money for some implied services (future or past), then that could be an issue if the law prohibits people under US jurisdiction to provide any services to them.

In this case the donor would merely be a sanctions violator, while tornado.cash is sanctioned. So the money isn't coming directly from a sanctioned entity.

I was reading and I think 18 USC 1957 may be a problem.

> Whoever, in any of the circumstances set forth in subsection (d), knowingly engages or attempts to engage in a monetary transaction in criminally derived property of a value greater than $10,000 and is derived from specified unlawful activity, shall be punished as provided in subsection (b).

The withdrawal from Tornado Cash after the sanctions were imposed is the specified unlawful activity (IEEPA violation).

Even if the withdrawal itself was legal (the person who withdrew the money was not a US person), the government could argue that he should have known the funds could have came from some crime, i.e:

> In a prosecution for an offense under this section, the Government is not required to prove the defendant knew that the offense from which the criminally derived property was derived was specified unlawful activity.

> Even if the withdrawal itself was legal (the person who withdrew the money was not a US person), the government could argue that he should have known the funds could have came from some crime, i.e:

I think you’re misreading that. The Government has to prove that the defendant knew that the property was criminally derived, but the government does not have to prove that the defendant was aware of the list of specific unlawful activities.

You’re right I misread that. I still think an overzealous prosecutor could find some violation, especially if p2p exchanges are used. They have charged people with operating an unlicensed money transmitter for merely being a customer of an unlicensed money transmitter!