The Significance of Tornado Cash as a Target of Sanctions

As a former Special Agent with the U. S. Secret Service, Rita was the lead case agent responsible for several complex financially motivated cybercrime investigations. Her former casework targeted high-risk cryptocurrency exchanges and other infrastructure that allowed top-tier cybercriminals to operate with impunity and anonymity. As a trained network intrusion responder, Ms. Martin also brings expertise of digital forensics, malware typing, and web application security to the team at TRM. Today. Ms. Martin builds TRM Academy, the global learning platform designed to educate and empower people to protect the blockchain ecosystem. She has developed and delivered training for law enforcement at centers of excellence around the world like the National Computer Forensics Institute (NCFI), International Law Enforcement Academies (ILEAs), and The CEELI Institute, among others.

Aaron Arnold is a Senior Associate Fellow with the Centre for Financial Crime and Security Studies at RUSI, where his work focuses on sanctions and proliferation financing.

Prior to joining RUSI, Aaron served as the finance and economics expert on the UN Panel of Experts for DPRK sanctions, where he monitored global sanctions implementation and investigated instances of sanctions violations. Before joining the Panel of Experts, Aaron was a fellow with the Project on Managing the Atom at the Harvard Kennedy School's Belfer Center, where he published work on the extraterritorial use of sanctions and the efficacy of WMD trade controls.

He also previously worked as a counter-proliferation subject matter expert in the U.S. Department of Defense and the U.S. Justice Department, where he specialized in WMD counter-proliferation investigations and operations, with an emphasis on threat finance and sanctions evasion.

Aaron holds a PhD and MPP in public policy and national security from George Mason University and a BA in political science from Virginia Tech.

Tom Armstrong currently serves as TRM's Compliance Advisor where he provides expert guidance and advisory support to traditional financial institutions, emerging crypto businesses, and regulators on industry best practices for the detection and prevention of money laundering and financial crime within digital assets. Prior to joining TRM, Tom spent over nine years at Goldman Sachs leading various investigative teams. He served as the Head of Financial Crime Compliance Digital Assets at Goldman Sachs, leading the strategic efforts to build the bank’s first dedicated financial crime compliance team covering blockchain-based assets. He also served as the Global Head of the Forensics Group, Head of the Financial Intelligence Unit, and Transaction Surveillance Group. He earned his Juris Doctorate from the University of Tulsa College of Law where he specialized in International Law.