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Privacy Policy

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These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Who we share your data with

If you request a password reset, your IP address will be included in the reset email.

How long we retain your data

 If you leave a comment, the comment and its metadata are retained indefinitely. This is so we can recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.

For users that register on our website (if any), we also store the personal information they provide in their user profile. All users can see, edit, or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.

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If you have an account on this site, or have left comments, you can request to receive an exported file of the personal data we hold about you, including any data you have provided to us. You can also request that we erase any personal data we hold about you. This does not include any data we are obliged to keep for administrative, legal, or security purposes.

Where your data is sent

Visitor comments may be checked through an automated spam detection service.

 

BlockDivers Privacy Protocol – Legal Use and Compliance Policy

Document Title: Privacy Protocol Policy
Version: 3.2
Effective Date: October 2025
Prepared By: BlockDivers Compliance Office
Reviewed By: Legal Counsel 

1. Purpose

The purpose of this Privacy Protocol Policy is to define how BlockDivers and its personnel may lawfully use, test, and evaluate privacy-enhancing blockchain technologies (such as Railgun, Aztec, Penumbra, and similar zk-based systems) within the scope of forensic, investigative, and educational research activities.

This policy ensures that all activity related to privacy protocols remains fully compliant with U.S. law, including applicable regulations of the U.S. Department of the Treasury (OFAC & FinCEN), the Internal Revenue Service (IRS), and any other relevant federal or state authorities.

2. Scope

This policy applies to:

  • All employees, contractors, and agents of BlockDivers.

  • Any wallets, smart contracts, or blockchain accounts created for testing or research.

  • All forensic, simulation, and traceability exercises using privacy protocols or zero-knowledge systems.

3. Policy Statement

BlockDivers supports the responsible, transparent, and lawful use of blockchain privacy technologies for legitimate purposes such as:

  • Academic and forensic research.

  • Testing detection and attribution methods (e.g., via AnChain.ai tools).

  • Educating clients and agencies about the forensic limitations of emerging privacy systems.

  • Evaluating the efficacy of trace techniques within lawful frameworks.

BlockDivers strictly prohibits:

  • Any use of privacy tools for money laundering, terrorism financing, sanctions evasion, concealment of illicit assets, or tax evasion.

  • Any interaction with smart contracts, addresses, or entities designated under U.S. Treasury sanctions lists (OFAC SDN List).

  • Custodial operations, mixing services, or relayer functions on behalf of external clients without explicit regulatory licensing.

4. Legal Foundations

This policy aligns with:

  • FinCEN (2019) “Guidance on Convertible Virtual Currency” — defining non-custodial activities as non-MSB operations.

  • OFAC (2023) “Sanctions Compliance Guidance for the Virtual Currency Industry.”

  • OFAC Designation of Tornado Cash and related sanctioned mixers (2022).

  • U.S. Code Title 18, Section 1956 (Money Laundering) and related statutes.

  • IRS Notice 2014-21 – Tax treatment of virtual currencies.

BlockDivers acknowledges that privacy-preserving protocols, when used for legitimate and transparent purposes, are not prohibited technologies under current U.S. law.

5. Authorized Use Cases

The following activities are authorized under this policy:

  1. Controlled Experiments: Shielding/unshielding of self-owned test assets to analyze forensic traceability and timing correlation.

  2. Educational Demonstrations: Demonstrating to clients how privacy pools operate and how forensic tools can identify entry/exit patterns.

  3. Protocol Evaluation: Assessing zk-based projects for potential forensic or compliance applications.

  4. Data Collection: Capturing anonymized transaction data for use in forensic training or product development.

All tests must:

  • Be documented (time, addresses, chain, intent, and protocol).

  • Use testnets or micro-valued mainnet funds owned by BlockDivers.

  • Avoid any third-party or client-owned funds.

6. Prohibited Activities

The following are expressly prohibited:

  • Use of any sanctioned or blacklisted smart contract (e.g., Tornado Cash contract addresses per OFAC).

  • Providing, hosting, or operating mixing or custodial services.

  • Assisting third parties to hide asset origin or ownership.

  • Use of privacy protocols to move or conceal funds with known criminal or sanctioned origin.

  • Using false identities or documents to access regulated exchanges or financial institutions.

7. Compliance Procedures

To ensure adherence:

  1. Pre-Test Review: Each new privacy test must be logged in the internal Experiment Register and approved by the Compliance Officer.

  2. Logging: Record wallet addresses, chain, timestamps, and tx hashes for every test.

  3. OFAC Screening: Prior to protocol interaction, verify that no smart contract or address involved is on an OFAC sanctions list.

  4. Reporting: Generate post-test reports for archival and, if necessary, legal review.

  5. Audit Readiness: Maintain all logs for five (5) years for compliance audits.

8. Roles & Responsibilities

  • Compliance Officer: Oversees privacy protocol use and ensures sanctions screening.

  • Investigators / Analysts: Conduct tests only after approval; report results and anomalies.

  • Legal Advisor: Reviews any regulatory updates and issues formal guidance as needed.

  • Management: Ensures resources and oversight for compliance adherence.

9. Disclaimer

This policy is not legal advice. BlockDivers’ use of privacy protocols remains subject to ongoing regulatory interpretation.
Employees must consult counsel or the Compliance Officer before expanding activities beyond approved research parameters.

10. References

  • FinCEN. Application of FinCEN’s Regulations to Certain Business Models Involving Convertible Virtual Currencies. 2019.

  • OFAC. Sanctions Compliance Guidance for the Virtual Currency Industry. October 2023.

  • U.S. Treasury Press Release. OFAC Sanctions Virtual Currency Mixer Tornado Cash. August 8, 2022.

  • Railgun.org. Project Documentation & Compliance Statement. 2025.

✅ Authorized by:
Dan Lounsbury
CEO, BlockDivers

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