# Roman Semenov **Roman Semenov** is the other co-author of [[Tornado Cash]]. A Russian national, he was indicted with [[Roman Storm]] on August 23, 2023 on the same three conspiracy counts (money laundering, sanctions violations and unlicensed money transmitting). He **remains at large**. The FBI says he has ties to Turkey, Dubai and Moscow. No change in his status was reported through 2026. ## Sanctioned twice, delisted once The same day as the indictment, the Treasury's [[Office of Foreign Assets Control]] designated him personally on two grounds: cyber-enabled activities (EO 13694) and North Korea (EO 13722), for helping launder funds stolen by the DPRK's [[Lazarus Group]]. Then the government's theory of the case changed: - **Nov 26, 2024.** In *[[Van Loon v. Department of the Treasury]]* the Fifth Circuit held that Tornado Cash's immutable smart contracts are not "property" that can be sanctioned. No one owns them. - **Mar 21, 2025.** OFAC delisted Tornado Cash, its website and 94 Ethereum addresses. Semenov's own entry was **updated, not removed**: the cyber basis was dropped, but the North Korea basis was kept. OFAC then told the court the *Van Loon* case was moot. The asymmetry is the government's revised position in a single act. The tool was never the right defendant; the developer still is. Treasury unwound the sanction on the code while keeping the sanction on the man who wrote it. ## See Also - [[Tornado Cash]] · [[Roman Storm]] · [[Van Loon v. Department of the Treasury]] - [[Office of Foreign Assets Control]] · [[Lazarus Group]] · [[North Korea]] · [[Specially Designated Nationals List]]