Fellow Benjamin Gruenstein, and his colleagues Evan Norris and Daniel Barabander challenge the legal foundation of the Tornado Cash indictment by providing an insightful analysis of the Bank Secrecy Act and FinCEN's 2019 guidance, which provides a principle-based rubric for defining money transmission, with a comprehensive and understandable description of the underlying code at issue.

Ben Gruenstein expressed the uncertainty of many when he asked, "What does 'undue delay' mean?" in the context of a new Justice Department approach to corporate enforcement policies.

Thank you to Fellows Jonathan Sack, Ben Gruenstein, Lucinda Low and Fred Davis for filing an amicus on behalf of The Academy in the Rafoi case.