According to Wu Blockchain, Roman Semenov, the Russian co-founder of Tornado Cash, has been added to the US OFAC's Specially Designated Nationals (SDN) List. Semenov is located in Dubai, and the announcement includes his eight Ethereum addresses. He is involved in secondary sanctions risk related to the North Korea Sanctions Regulations, with transactions prohibited for persons owned or controlled by U.S. financial institutions. The implications of this designation on Semenov and Tornado Cash are yet to be determined.

The US OFAC (Office of Foreign Assets Control) SDN (Specially Designated Nationals) List is a list of individuals, entities, and organizations that are subject to economic and trade sanctions based on United States foreign policy and national security objectives. The reasons for inclusion on the list may include involvement in terrorism, narcotics trafficking, human rights abuses, or weapons of mass destruction proliferation.