Pryor Cashman Partner Jeffrey Alberts, who co-heads the firm’s FinTech Group, authored an article, “Sanctioning Code: What's Next for Crypto Sanctions?” for the New York Law Journal.

The article examines potential Office of Foreign Asset Control (OFAC) overreach in sanctioning a blockchain protocol known as Tornado Cash, and the resulting legal battle that could decide the future of blockchain technology.

"OFAC appears to believe that it has legal authority not only to sanction entities, but to sanction technological instrumentalities that are used by these entities, such as smart contracts and computer programs."

"If OFAC can sanction smart contracts and protocols making use of smart contracts by asserting that the programs were used by bad actors to threaten national security, could it sanction a blockchain token, or even the native asset of a blockchain, such as Bitcoin, and prohibit all transfers involving these digital assets?"

Read the full article using the link above.