Moderate risk — proven privacy technology with the largest anonymity set in DeFi, offset by governance vulnerabilities, regulatory uncertainty, and supply chain security concerns.
Risk Breakdown
Top Risks
Governance was compromised in May 2023 when an attacker used a malicious proposal with hidden SELFDESTRUCT/CREATE2 logic to grant themselves 1.2M votes, exceeding the legitimate 700K votes. The attacker later returned control, but the attack vector demonstrated that DAO proposal auditing is insufficient to prevent governance takeover.
Co-founder Roman Storm was convicted on one count (operating an unlicensed money transmitter) in 2024 and faces retrial in October 2026 on two additional unresolved counts — money laundering conspiracy and sanctions violations conspiracy. Co-founder Alexey Pertsev was convicted in the Netherlands (May 2024, 64 months) with his appeal ongoing as of mid-2026. These prosecutions establish legal precedent that privacy protocol developers face criminal liability, maintaining elevated regulatory risk even after OFAC sanctions were lifted in March 2025.
The protocol's anonymity set degrades at low usage periods — fewer deposits and withdrawals in a given pool denomination make it easier to correlate transactions. TVL volatility driven by regulatory uncertainty directly impacts privacy guarantees.
A supply chain attack implanted backdoor code in the Tornado Cash npm package, marking the second major security breach after the governance hack. This highlights risks in the protocol's open-source maintenance model post-sanctions.
Frequently Asked Questions
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