Tornado Cash, then, is a network of peer-to-peer channels, rather than a discrete company, entity or service. So while the sanctioning document targets Tornado Cash by name, and lays out a series of specific Ethereum addresses associated with it, the code could in principle be redeployed under a different name and utilizing different addresses. It seems likely this would set up a kind of “whack-a-mole” situation as new iterations of Tornado Cash are sanctioned as quickly as they appear.
