Secret Notes And Anonymous Coins: Examining FinCEN’s 2019 Guidance On Money Transmitters In The Context Of The Tornado Cash Indictment
Fellow Benjamin Gruenstein, and his colleagues Evan Norris and Daniel Barabander challenge the legal foundation of the Tornado Cash indictment by providing an insightful analysis of the Bank Secrecy Act and FinCEN's 2019 guidance, which provides a principle-based rubric for defining money transmission, with a comprehensive and understandable description of the underlying code at issue.