On November 26, 2024, the Fifth Circuit Court of Appeals held that the United States Office of Foreign Assets Control (“OFAC”) exceeded its authority by adding an entity that pools and anonymizes crypto transactions to OFAC’s Specially Designated Nationals and Blocked Persons list (“SDN list”).  Van Loon, et al. v. Dep’t of Treasury, et al., No. 23-50669, — F.4th — (5th Cir. Nov. 26, 2024).