[legutierr]

> considering the Tornado Cash protocol an unregulated bank which it is

This is a very strong statement to make without also making a legal argument to back it up.

Just because you assert that it is a bank does not make it so. What precedents, statutes and regulations would you cite to support your assertion?

[x-complexity]

Seconded. The actions that can be done with Tornado Cash are specific & finitely-defined: Even if it could be translated into regular banking terms, what Tornado does is not something that a normal bank does, & what Tornado provides is nowhere near the functionality that a regular bank performs for its depositors/lenders.