This article sets forth a First Amendment argument challenging the decision made by the United States Department of the Treasury, Office of Foreign Asset Control (âOFACâ) to sanction virtual currency mixer Tornado Cash by adding it to the Specially Designated Nationals List (âSanctions Listâ). United States citizens are prohibited from transacting with individuals and entities on the Sanctions List. OFAC targeted Tornado Cash because it enables users to transact on the blockchain with some level of anonymity. OFAC alleges that Tornado Cash has been used by criminals for illicit financing.