Several weeks ago, OFAC sanctioned Tornado Cash adding the service and related wallets to their sanctioned entity list. Coin Center, a D.C. based think tank group immediately went on the attack with legal analysis, specifically how the Treasury Department was likely overstepping its authority on shaky legal grounds. On August 25th, they published a detailed explainer of how Tornado Cash works.
coincenter.substack.com
On Friday, September 6, OFAC released amendments to Cyber-related Sanctions regs, and appears to create a broad brush stroke sweeping definition of "services" (at least that's what I read at first pass. continuing to digest).
See the entire reg attached below:

How does Tornado Cash actually work?
When a person uses the Tornado Cash contracts to protect their privacy, they arguably are not even engaged in the kinds of activities that can be sanctioned.

On Friday, September 6, OFAC released amendments to Cyber-related Sanctions regs, and appears to create a broad brush stroke sweeping definition of "services" (at least that's what I read at first pass. continuing to digest).
See the entire reg attached below: