Mixers targeted
United States
No federal rule bars privacy coins, but mixer developers have been prosecuted and Tornado Cash was under US sanctions from 2022 to 2025.
The rule
- Exchange listing
- Allowed
- Holding by individuals
- Allowed
- Mixers
- Sanctioned or prosecuted
- Self-hosted wallets
- No specific rule
- Confidence
- Confirmed
No federal law or regulator rule bars individuals from holding privacy coins or exchanges from listing them: on 13 October 2026 the public APIs of Coinbase and Gemini showed Zcash (ZEC) markets, Coinbase returned no XMR-USD market, Kraken's API showed XMR and ZEC pairs online, and Kraken's country restrictions page (updated 30 September 2026) set no US limit on either coin. OFAC designated the Tornado Cash mixer on 8 August 2022 and removed it on 21 March 2025, after the Fifth Circuit held in Van Loon v. Department of the Treasury (26 November 2024) that its immutable smart contracts are not property that can be blocked under IEEPA. Criminal cases against mixer developers continue: Roman Storm of Tornado Cash was convicted on 6 August 2025 of conspiring to operate an unlicensed money transmitting business, and his retrial on the undecided money laundering and sanctions counts was reported in August 2026 as postponed to 26 April 2027 while his motion for acquittal is pending; the two Samourai Wallet founders were sentenced in November 2025 to five and four years for a money transmitting conspiracy that knowingly moved criminal proceeds. A Deputy Attorney General memo of 7 April 2025 said the Justice Department would no longer target mixing and tumbling services for the acts of their end users or unwitting regulatory violations, except where that fits its stated priorities, and told prosecutors not to charge regulatory violations such as unlicensed money transmitting under 18 U.S.C. § 1960(b)(1)(A) and (B) without evidence of a wilful violation; it does not name the (b)(1)(C) limb on transmitting criminal proceeds. FinCEN announced on 5 October 2026, and the Federal Register published on 6 October 2026, the withdrawal of its 2023 proposal to treat international mixing as a class of transactions of primary money laundering concern.
Instrument: OFAC sanctions on Tornado Cash (2022 to 2025); DOJ prosecutions under 18 U.S.C. § 1960
Sources
- U.S. Treasury Sanctions Notorious Virtual Currency Mixer Tornado Cash
- Van Loon v. Department of the Treasury, No. 23-50669, opinion
- Tornado Cash Delisting
- Ending Regulation By Prosecution, memorandum for all Department employees
- Founder of Tornado Cash crypto mixing service convicted of knowingly transmitting criminal proceeds
- Roman Storm Retrial Delayed to April 2027
- Founders of Samourai Wallet cryptocurrency mixing service sentenced to five and four years in prison
- FinCEN Announces Withdrawals of Proposed Digital Asset Related Rules
- Proposal of Special Measure Regarding Convertible Virtual Currency Mixing, as a Class of Transactions of Primary Money Laundering Concern; Withdrawal (91 FR 63513)
- Coinbase Exchange API: ZEC-USD product
- Coinbase Exchange API: XMR-USD product (not found)
- Gemini API: symbols
- Kraken REST API: AssetPairs
- Cryptocurrencies available on Kraken
- Where is Kraken licensed or regulated?
Self-hosted wallets
No specific rule
No federal rule sets requirements for withdrawals to self-hosted wallets: the funds travel rule passes information between financial institutions on transmittals of USD 3,000 or more, and FinCEN withdrew its December 2020 unhosted-wallet proposal as of 6 October 2026.
The withdrawn proposal (85 FR 83840, 23 December 2020) would have required banks and money services businesses to keep records, verify customers' identities and file reports for convertible virtual currency transactions involving unhosted wallets or wallets hosted in jurisdictions identified by FinCEN; the withdrawal notice (91 FR 63514, published 6 October 2026) says FinCEN will take no further action on it. FinCEN guidance FIN-2019-G001 of 9 May 2019 applies the Funds Travel Rule in 31 CFR 1010.410(f) to transmittals of USD 3,000 or more in convertible virtual currency and says a person using an unhosted wallet to buy goods or services on their own behalf is not a money transmitter. Any checks on self-hosted withdrawals therefore come from exchanges' own policies or state regulators, which were not checked here.
Privacy coins and wallets: No federal rule bars transfers to privacy wallets or shielded addresses: FinCEN's 2019 guidance leaves money transmitters to decide on a risk basis when to accept or transmit anonymity-enhanced currencies and, where the Funds Travel Rule applies, to trace them and identify the sender or recipient (section 4.5.3), and on 5 October 2026 FinCEN announced the withdrawal of its proposal to treat convertible virtual currency mixing as a class of transactions of primary money laundering concern.
- Requirements for Certain Transactions Involving Convertible Virtual Currency or Digital Assets; Withdrawal (91 FR 63514)
- FinCEN Announces Withdrawals of Proposed Digital Asset-Related Rules
- FIN-2019-G001: Application of FinCEN's Regulations to Certain Business Models Involving Convertible Virtual Currencies
US states
US states
ZEC is not on the NYDFS Greenlist, which in its newest capture (13 Oct 2026) named only bitcoin, ether and six tokens approved for issuance in New York (four dollar stablecoins, a yen stablecoin and a gold token), and it was absent from the 2021 version too. DFS guidance of 15 Nov 2023 says a coin with features designed to facilitate the obfuscation or concealment of identity cannot be self-certified by a BitLicensee or New York trust company, which leaves DFS approval of a firm-specific application as the only route to list such a coin while it is off the Greenlist; DFS names no coins. Gemini, a New York limited purpose trust company, has offered ZEC since DFS authorised it to do so on 14 May 2018, and its US help centre list (updated 5 Oct 2026) flags no New York limit on ZEC, while Coinbase, which left New York out of its 2018 ZEC launch, was reported to have opened ZEC to New York residents on 10 Feb 2020. Kraken, Binance.US and OKX US do not serve New York residents, so none of the other six coins tracked here is available to New Yorkers on the exchanges checked.
State limits on the exchanges checked
- Coinbase (ZEC): no state exclusion found, New York included (reported).
- Kraken (ZEC, XMR and DCR): not offered in Maine or New York.
- Gemini (ZEC): no state exclusion found, New York included.
- Binance.US (ZEC; not one of the exchanges in the table): not offered in Alaska, Connecticut, Georgia, Maine, New York, North Carolina, North Dakota, Ohio, Oregon, Texas, Vermont, Washington, American Samoa, Guam, the Northern Mariana Islands or the US Virgin Islands.
- OKX US (ZEC): not offered in New York, American Samoa, Guam, the Northern Mariana Islands or the US Virgin Islands (not verified).
- KuCoin (ZEC, XMR and DCR): serves no US state.
- Bitfinex (ZEC and XMR): serves no US state.
Notes by exchange, federal rules, five more states and sources
- Coinbase
- The Coinbase pages that could be read set no state limit on ZEC but do not address state coverage: the US price page (archived 23 Aug 2026) flags ZEC as tradable for country US and the US how-to-buy page (archived 10 Jul 2026) says ZEC can be bought in the United States. Coinbase, Inc. has held a New York virtual currency licence since January 2017; its 5 Dec 2018 ZEC launch left out New York residents, and The Block reported that Coinbase opened ZEC to them on 10 Feb 2020. No Coinbase page confirming current New York or state-by-state availability could be opened, as coinbase.com and help.coinbase.com refused direct requests (HTTP 403).
- Kraken
ZEC: Kraken does not serve residents of Maine or New York (licensing page updated 30 Sep 2026); its Maine service ended on 1 Jun 2024. ZEC is not on the page's list of assets restricted for US clients, and ZEC/USD and ZEC/EUR are online in the public API (19 Oct 2026). The page says residents of Texas and New Hampshire cannot deposit or hold EUR or trade EUR pairs, which rules out ZEC/EUR for them; its Indiana limit on crypto transfers is listed under restrictions for Krak, Kraken's standalone payments app whose balances are kept separate from Kraken accounts.
XMR: Kraken does not serve residents of Maine or New York (licensing page updated 30 Sep 2026). XMR is not on the page's list of assets restricted for US clients, and XMR pairs against USD, USDC, USDT, XBT and EUR are online in the public API (19 Oct 2026), which makes Kraken the only US-serving exchange checked here with an XMR market. Residents of Texas and New Hampshire cannot trade EUR pairs, so XMR/EUR is closed to them; the page's Indiana limit on crypto transfers is listed under restrictions for Krak, Kraken's standalone payments app.
DCR: Kraken does not serve residents of Maine or New York (licensing page updated 30 Sep 2026). DCR is not on the page's list of assets restricted for US clients, and DCR/USD is online in the public API (19 Oct 2026), which makes Kraken the only US-serving exchange checked here with a DCR market; the page's Indiana limit on crypto transfers is listed under restrictions for Krak, Kraken's standalone payments app.
- Gemini
- Gemini says it serves all 50 US states (article edited 24 Apr 2025). Its US help centre list of supported cryptos (updated 5 Oct 2026) flags a ZEC restriction only for Singapore, and flags New York limits for USDT and GRAM but none for ZEC. DFS authorised Gemini, a New York limited purpose trust company, to offer ZEC trading and custody on 14 May 2018; Gemini opened ZEC deposits on 19 May 2018 and trading on 22 May 2018.
- Binance.US
- Binance.US (BAM Trading Services) is separate from the Binance global platform in the matrix and is not one of the 14 tracked exchanges. Its API shows ZEC/USD and ZEC/USDT trading and no symbol for the other six coins (19 Oct 2026), and its listings page (updated 9 Sep 2026) gives the native Zcash network with no state-specific limit on ZEC. It does not register residents of 12 states and four territories (article dated 3 Jun 2026), and in Kansas and Wisconsin it offers crypto-only service without USD deposits.
- OKX US
- US customers are served by OKX Inc. (OKX US), which does not serve residents of New York or four territories (licences page updated 15 Sep 2026); the global platform in the matrix has listed ZEC-USDT since 24 Nov 2025. Whether OKX US itself offers ZEC could not be confirmed: its public instruments API at us.okx.com returns the same 1,184 spot instruments as www.okx.com, the United States-locale ZEC price page carries the same LISTED flag as the page on www.okx.com, and no OKX US asset list was found.
- KuCoin
- KuCoin agreed in its US guilty plea of 27 Jan 2025 to exit the US market for at least the next two years, and its terms of use (updated 29 Sep 2026) list the United States and its territories as restricted locations, so it serves no US state; this applies to every coin on KuCoin.
- Bitfinex
- Bitfinex's terms bar every US person, covering the states of the United States and the District of Columbia and including US citizens, permanent residents and passport holders (FAQ edited 17 Oct 2026), so it serves no US state; this applies to every coin on Bitfinex.
- Federal rules
- No federal statute or regulator rule bars US persons from holding or trading privacy coins, or exchanges from listing them, so access turns on state licensing and each platform's own listing and residency rules; the Zcash Foundation said on 14 Jan 2026 that the SEC had closed an inquiry into it without recommending enforcement action. The federal sanctions and rule-making most relevant here concern mixers and unhosted-wallet transfers rather than the coins themselves: Treasury removed its Tornado Cash sanctions on 21 Mar 2025, and FinCEN withdrew its 2023 proposed special measure on convertible virtual currency mixing and its 2020 proposed reporting and verification rule for transactions with unhosted wallets (announced 5 Oct 2026, published 6 Oct 2026).
- Texas
- No Texas regulator action naming privacy coins was found. The Department of Banking's Supervisory Memorandum 1037 (revised 28 Jan 2025) does not mention privacy features and says that receiving non-stablecoin virtual currency for transmission is not, by itself, money transmission under the Money Services Modernization Act, though transactions involving sovereign currency or stablecoins may be. Binance.US does not serve Texas residents; Kraken does, but says they cannot deposit or hold EUR or trade EUR pairs (a limit it listed in 2025 among its state funding restrictions), and OKX US holds a Texas money transmission licence and does not exclude the state.
- Washington
- No Washington regulator action naming privacy coins was found. The Uniform Money Services Act counts virtual currency as equivalent value in its definition of money transmission (RCW 19.230.010), and the Department of Financial Institutions' consumer page mentions anonymity only to say that virtual currency transactions are recorded on a public blockchain, naming no coin. Binance.US does not serve Washington residents, while Gemini and OKX US, which holds a Washington money transmitter licence, do not exclude the state; Kraken still listed Washington among the states it did not serve in a capture of 21 Jun 2025 but no longer did in one of 7 Jul 2025 or on its current page.
- Hawaii
- No Hawaii regulator action naming privacy coins was found. The Department of Commerce and Consumer Affairs said on 25 Jan 2024 that the Digital Currency Innovation Lab would end on 30 Jun 2024 and that digital currency companies would no longer need a Hawaii money transmitter licence, because their activity did not fit the concept of money transmission in Chapter 489D. None of Binance.US, Kraken, Gemini or OKX US excludes Hawaii.
- California
- California's Digital Financial Assets Law bars digital financial asset business activity with residents from 1 Jul 2026 unless the firm is licensed, applied for a licence on or before that date and awaits a decision, or is exempt. It requires an exchange to certify each listed asset to the Department of Financial Protection and Innovation after assessing securities status, conflicts of interest, and cybersecurity, fraud and market risks, and none of the listed factors concerns privacy features; assets approved for listing by NYDFS under its Part 200 rules on or before 1 Jan 2023 need no certification. No California action naming privacy coins was found.
- Maine
- Kraken has not served Maine residents since 1 Jun 2024 and Binance.US does not register them, so Maine residents have no XMR or DCR market on the exchanges checked, while Gemini, which serves all 50 states, still offers them ZEC. Kraken gives no reason beyond saying the SEC lawsuit against it was not a factor, Binance.US says only that an unsupported state may reflect pending regulatory approvals, and no Maine regulator statement was checked.
Sources
- Tornado Cash Delisting
- FinCEN Announces Withdrawals of Proposed Digital Asset Related Rules
- Requirements for Certain Transactions Involving Convertible Virtual Currency or Digital Assets; Withdrawal (91 FR 63514), withdrawing the proposed rule at 85 FR 83840 of 2020-12-23
- Proposal of Special Measure Regarding Convertible Virtual Currency Mixing, as a Class of Transactions of Primary Money Laundering Concern; Withdrawal (91 FR 63513), withdrawing the proposal at 88 FR 72701 of 2023-10-23
- Notice Concluding SEC Investigation
- Where is Kraken licensed or regulated?
- What cryptos are supported on the Gemini Exchange? (US help centre, API copy)
- Virtual Currency Businesses, Greenlisted Coins section (archived copy of 2026-10-13)
- Industry letter: General Framework for Greenlisted Coins (archived copy of 2026-06-10)
- Greenlisted Coins/Tokens, updated 2021-10-04 (archived copy of 2022-01-14)
- Industry letter: Guidance Regarding Listing of Virtual Currencies (archived copy of 2026-09-30)
- Virtual Currency Businesses, regulated entities, listing paths and Greenlisted Coins sections (archived copy of 2026-10-13)
- DFS Authorizes Gemini Trust Company to Provide Additional Virtual Currency Products and Services (archived copy of 2020-02-26)
- Gemini Is Now the World's First Licensed Zcash Exchange!
- Buy and Sell ZEC on Coinbase (archived copy of 2025-02-11)
- New York residents can now trade USDC and Zcash on Coinbase
- List of supported and unsupported states and regions
- U.S. Licenses
- Zcash price page, US locale, showing ZEC as tradable for country US (archived copy of 2026-08-23)
- How to buy Zcash on Coinbase in United States (archived copy of 2026-07-10)
- Virtual Currency Businesses, regulated entities section (archived copy of 2026-10-13)
- Changes that affected our Maine clients
- Kraken public API: AssetPairs (ZEC/USD and ZEC/EUR online)
- What is Krak and how's it different from Kraken's other apps?
- Kraken public API: AssetPairs (XMR/USD, XMR/USDC, XMR/USDT, XMR/XBT and XMR/EUR online)
- Kraken public API: AssetPairs (DCR/USD online)
- Which countries and U.S. states does Gemini support? (US help centre, API copy)
- Binance.US API: exchangeInfo (ZECUSD and ZECUSDT trading; no XMR, DCR, ZANO, ARRR, XVG or FIRO symbols)
- Listings on Binance.US: supported crypto, networks, and trading pairs
- OKX public instruments API, spot, requested via us.okx.com (returns the same 1,184 instruments as www.okx.com; ZEC-USDT listed from 2025-11-24)
- Zcash price page, United States locale (page type LISTED, ZEC/USDT pair)
- Zcash price page on www.okx.com, served here as OKX Europe (page type LISTED)
- KuCoin Pleads Guilty To Unlicensed Money Transmission Charge And Agrees To Pay Penalties Totaling Nearly $300 Million (archived copy of 2025-01-28)
- Terms of Use (Restricted Locations)
- U.S. Person: Frequently Asked Questions (FAQ) (help centre API copy)
- Supervisory Memorandum 1037: Regulatory Treatment of Virtual Currencies Under the Money Services Modernization Act (rev. 2025-01-28)
- Where is Kraken licensed or regulated? (archived copy of 2025-06-21, Texas and New Hampshire EUR limits under state-by-state funding restrictions)
- RCW 19.230.010: Definitions (Uniform Money Services Act)
- Virtual Currency, Cryptocurrency, and Digital Assets Information for Consumers
- Where is Kraken licensed or regulated? (archived copy of 2025-06-21, Washington listed as not served)
- Where is Kraken licensed or regulated? (archived copy of 2025-07-07, only Maine and New York listed as not served)
- Hawaii Digital Currency Innovation Lab To Conclude
- California Financial Code section 3201 (Digital Financial Assets Law, licence requirement), FindLaw copy current as of 2026-01-01
- California Financial Code section 3505 (Digital Financial Assets Law, listing certification), FindLaw copy current as of 2026-01-01
Exchanges and their restrictions
The 14 exchanges on this site, with the 32 spot markets they list for the seven coins, as checked on 13 Oct 2026. The exchange data records where each listing is restricted as text, so this page quotes each passage that names the United States, and marks the cells it comes from. An exchange with no such passage has no restriction for the United States on record here, which does not mean that it is licensed there or open to its residents. A listing is not an endorsement.
Swipe the table sideways to see all seven coins.
| Exchange | ZECZcashSpot on 11, perp only on 1 | XMRMoneroSpot on 6, perp only on 3 | DCRDecredSpot on 6 | ZANOZanoSpot on 1 | ARRRPirate ChainSpot on 2 | XVGVergeSpot on 4, perp only on 3 | FIROFiroSpot on 2 |
|---|---|---|---|---|---|---|---|
| Binance | Restricted +perpApr 2025Shielded in: noShielded out: no | DelistedFeb 2024Perp only | RestrictedApr 2025 | Never listed | Never listed | Listed +perpWithdrawals frozen | DelistedApr 2025 |
| Coinbase | Listed +perpNov 2018Shielded in: yesShielded out: no | Never listed | Never listed | Never listed | Never listed | Never listed | Never listed |
| Kraken | Restricted +perpJun 2026Shielded in: unknownShielded out: no | Restricted +perpJun 2026 | RestrictedMay 2026 | Never listed | Never listed | Never listed | Never listed |
| OKX | Listed +perpNov 2025Shielded in: unknownShielded out: unknown | DelistedJan 2024 | DelistedJul 2024 | Never listed | Never listed | Never listed | Never listed |
| Bybit | DelistedFeb 2025Perp only | Never listedPerp only | DelistedNov 2024 | Never listed | Never listed | Never listedPerp only | Never listed |
| Bitget | Listed +perpDec 2025Shielded in: unknownShielded out: unknown | Never listedPerp only | Never listed | Never listed | Never listed | Never listedPerp only | Never listed |
| KuCoin | Listed +perpJul 2019Shielded in: unknownShielded out: no | Listed +perpMar 2019 | ListedSep 2018 | Never listed | DelistedSep 2023 | Never listedPerp only | Never listed |
| Gate | Listed +perpShielded in: unknownShielded out: unknown | Restricted +perp | Listed | Never listed | ListedWithdrawals frozen | Restricted | Restricted |
| HTX | Listed +perpDec 2022Shielded in: noShielded out: no | Listed +perpDec 2022 | ListedDec 2022 | Never listed | Never listed | ListedDec 2022 | DelistedSep 2025 |
| MEXC | Listed +perpShielded in: unknownShielded out: unknown | Listed +perp | Listed | ListedDec 2023 | ListedJan 2024 | Listed +perp | Listed |
| Gemini | RestrictedMay 2018Shielded in: yesShielded out: yes | Never listed | Never listed | Never listed | Never listed | Never listed | Never listed |
| Bitfinex | Listed +perpOct 2016Withdrawals frozenNamed in a noteShielded in: unknownShielded out: unknown | ListedNov 2016Named in a note | DelistedMar 2022 | Never listed | Never listed | DelistedDec 2024 | Never listed |
| Crypto.com | Never listed | Never listed | Never listed | Never listed | Never listed | Never listed | Never listed |
| Upbit | DelistedSep 2019 | DelistedSep 2019 | DelistedDec 2020 | Never listed | Never listed | DelistedMay 2020 | DelistedMay 2020 |
Passages that name the United States
- All coins: Binance.US is a separate platform and is not covered
- All coins: Global platform at www.okx.com; regional entities (OKX Europe for the EEA, OKX US) are noted only where an OKX notice names them
- All coins: Global platform kucoin.com, not offered in its listed restricted locations (including the US, Singapore, France and the Netherlands);
- All coins: Global offshore platform; its user agreement (last updated 29 May 2025) bars all services to residents of the US, UK, Canada, Singapore, Hong Kong, Malaysia, mainland China, Kazakhstan, the Russian-controlled regions of Ukraine, North Korea, Cuba, Iran, Sudan and other comprehensively sanctioned or FATF blacklisted territories, so those users cannot trade any coin here
- All coins: Global spot platform; not open to US persons under its terms of service;
- ZEC Listed ZECUSD, ZECBTC and ZECUST trade today and the Bitfinex ZEC article names no regional restriction beyond the platform-wide exclusion of US persons;
- XMR Listed Bitfinex's verification page says certain tokens may be restricted in specific jurisdictions, but its XMR articles name no such restriction, so the only one found is the platform-wide exclusion of US persons (third-party blog claims of regional XMR limits were not supported by any Bitfinex notice).
Self-hosted wallets for the seven coins
The nine wallets on the Wallets page that hold at least one of the seven coins, with the coins and platforms each supports. The wallet data does not record where each wallet is offered, so this list is the same on every country page, and the United States's own rules, set out above, apply to their use. A listing is not an endorsement.