[downandout]

Yes, but the same intent provisions still apply to the entity that enabled the structuring. Tornado Cash has legitimate use cases - I had one prior to the OFAC issue (hiding the source of funds to an address in order to prevent certain bots from reacting to it). So the devs cannot have formed intent to aid in any of the crimes that TC may have unwittingly enabled.

Casinos are used as vehicles for structuring and money laundering every minute of every day - on a much larger scale than anything Tornado Cash could ever have achieved. They don't have the intent to aid in these activities though, which is why they are allowed to operate.

[300bps]

[Casinos] don't have the intent to aid in these activities though, which is why they are allowed to operate.

Casinos are allowed to operate because not only do they not have the intent to aid these activities, they happily track and report everything they're required which is just as much as a bank is required. They aren't the hotbed of money laundering you seem to think they are.

https://www.fincen.gov/resources/statutes-regulations/guidan...

https://casinogrounds.com/blog/know-your-customer-gambling/

[downandout]

They aren't the hotbed of money laundering you seem to think they are.

I spent a fair amount of time in the gaming business, and I can tell you that this statement is patently false. Very little of it gets caught, because the people involved in such schemes know what the rules are and simply work around them. Casinos themselves also sometimes turn a blind eye to such activity when it is especially profitable for them. Example [1]. That occurred even with the reporting requirements.

[1] https://www.justice.gov/usao-cdca/pr/operator-venetian-resor...

[300bps]

There really seems to be a lot of mental gymnastics going on here.

Your original point was that casinos are allowed to operate because of their "lack of intent". I respond that it's actually because they're as heavily regulated as banks are. Your response is, "But sometimes they break the law!"

Who cares? Casinos are heavily regulated and most of the time they follow their regulations. Or they would be shut down.

And here we go back to the real original point... what regulations were Tornado Cash following? Were they ever following AML/BSA regulations? Did they do anything significant to attempt to comply with regulations that all money exchange companies have to comply with?

Seriously, take 2 minutes and read this:

https://home.treasury.gov/news/press-releases/jy0916

Your little example of Casino money laundering was $47 million and was touted as “the largest all-cash, up-front gambler the Venetian-Palazzo had ever had to that point,”.

Now read that link from treasury.gov:

Tornado Cash, which has been used to launder more than $7 billion worth of virtual currency since its creation in 2019. This includes over $455 million stolen by the Lazarus Group, a Democratic People’s Republic of Korea (DPRK) state-sponsored hacking group

It's not even comparable. $47 million is 0.6% of $7 billion. Tornado Cash's raison d'être was money laundering and it was right to shut them down.

[vlovich123]

Out of curiosity, what was the total volume of funds processed over the same time period? I haven’t been able to find that anywhere.