Sanctions Implications for Zcash
summary
OFAC adds Tornado Cash sanctions under IEEPA and then the DOJ indicts Roman Storm for conspiracy, arguing published protocol code plus an AWS-hosted UI can enable sanctions evasion; Coin Center files an amicus brief invoking the Burman amendments and the Free Trade in Ideas Act to argue information transactions are exempt. Miners can exclude sanctioned transparent addresses but cannot practically filter shielded transactions, and developers are repeatedly warned to retain sanctions counsel.
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chapters (24)
- 0:00Intro
- 1:05Purpose of talk
- 1:43Tornado Cash Sanction
- 3:52Potential implications
- 4:12Explanation of sanctions laws
- 7:57Brief overview of sanctions laws
- 10:06Advice for developers on legal risks
- 13:04Overview of the IEEPA
- 17:12Limits of Sanctions Laws
- 17:30Intro to Berman Amendments and the Free Trade in Ideas Act
- 19:38Why we have these two laws
- 20:30Introduction to the "Free Trade and Ideas Act"
- 25:15Could a minor be persecuted?
- 29:40Mining with regard to shielded transactions
- 32:04Explanation of Tornados indictment against Roman Storm
- 34:10How would anonymity and no UI services affect those charges?
- 40:55When should Zcash devs hire lawyers?
- 42:27Is it better for Zcash to remove transparent transactions?
- 44:08Exemption of US entities from sanctions significant for ECC and ZF?
- 46:40Could increased regulations remove Zcash wallets from app stores? What then?
- 48:46Binance exchange addresses and Mica
- 49:30Legal implications of EIP 7547 in the Ethereum upgrade?
- 51:45Willful blindness
- 53:26Conclusion & info about accessing further resources
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