On November 26, 2024, in Van Loon v. Department of the Treasury, the Fifth Circuit held that OFAC exceeded its authority under the International Emergency Economic Powers Act (“IEEPA”) by sanctioning Tornado Cash, concluding that immutable smart contracts are not "property" subject to sanction. The court relied on the Supreme Court's decision in Loper Bright Enterprises v. Raimondo, which overruled Chevron deference, to reach its conclusion.