The OFAC designation of Tornado Cash in August 2022 was supposed to be a death blow to Ethereum-based mixing. In practice, it created a vacancy that the market has filled aggressively. Our research team has spent the past six months mapping every mixer, tumbler, and privacy tool that has launched since the designation, and grading each on its compliance exposure. Seventeen protocols meet our criteria for inclusion. Of those, eight are operationally active today.
We break the successors into three categories. Category A: protocols that attempted to be "sanctions-compliant" through sanctions screening on deposit. Three projects fit this description; two have shut down after failing to attract volume, and one remains marginally active. Category B: protocols that implemented decentralised governance to distance themselves from an operator. Five projects, three active. Category C: protocols that made no meaningful effort at compliance. Nine projects, three active but two operating from high-risk jurisdictions and one openly advertising to sanctioned users.
Volume tells the story. The Category A projects collectively processed $180 million in 2025. The Category B projects processed $2.4 billion. The Category C projects processed an estimated $6.7 billion — and we believe that figure is low by at least 30% due to the challenges of attributing anonymous, multi-chain, rapidly rotating infrastructure.
The practical implication is that "mixer exposure" no longer means "Tornado Cash exposure." Our updated mixer attribution covers all 17 protocols and their component pools, subject to ongoing maintenance. We also score transactions based on the mixer's compliance category, recognising that interaction with a Category A project is a different risk signal than interaction with Category C.
Among the successors, a few patterns are worth calling out. First, the prevalence of cross-chain designs. Unlike Tornado Cash, which operated only on Ethereum, every new project of significance supports at least three chains — typically Ethereum, BNB Chain, and Polygon. The top three also support Tron, reflecting the same migration pattern we see across illicit finance broadly.
Second, user-experience innovations. Modern mixers offer liquidity-pool interfaces that look indistinguishable from DEX LP provision, withdrawal scheduling that spreads output over days, and integration with prominent wallet UIs. For an inexperienced user, the compliance implications of a deposit may not be obvious.
Third, the emergence of privacy-preserving but attributable designs. A handful of projects — we call them "Category D" for clarity — allow users to cryptographically prove to a third party (e.g., an exchange) that they are not a sanctioned party, without revealing their identity. If these designs mature, they could shift the compliance conversation substantially, but adoption remains modest.
Enforcement is patchy. OFAC has added two successor projects to the SDN list in 2025. UK and EU regulators have taken no equivalent action to date. Law enforcement interest varies: FBI and DOJ investigations are ongoing, but public indictments have been rare. Civil suits have been more active, with class actions targeting both project developers and incidentally-implicated DEX aggregators.
From a screening perspective, our guidance remains simple. Treat any interaction with a Category B or C protocol as an elevated risk signal. Document your risk-appetite threshold for these categories and apply it consistently. Do not rely solely on names — the ecosystem rotates, and project names are a weak attribution signal. Our database resolves addresses to underlying protocol-level attribution, which survives rebrands.
We plan to refresh this research quarterly. Enterprise customers can download the full mapping — including pool-level attribution, volume estimates, and compliance grades — from the research portal. The next update will land in late June 2026.
