★ Deployer linked within 3 hops to DPRK/Lazarus

Evidence summary #

Per U15 / §7-rule-5 framing: YELLOW, NOT red. The U.S. SEC filed a civil action (LR-26496, 2023-03-22) against Justin Sun personally, Tron Foundation, BitTorrent Foundation, Rainberry Inc. for alleged market manipulation and unregistered securities. SETTLED ~2026-03-05: Rainberry paid $10M civil penalty; all claims against Justin Sun, Tron Foundation, BitTorrent Foundation dismissed WITH PREJUDICE (CoinDesk 2026-03-05; Crowdfund Insider 2026-03-05). This is a settled US SEC CIVIL action with ZERO OFAC SDN designation, ZERO DPRK/Lazarus cluster nexus, and ZERO sanctions linkage. The 2022-08-13 Tornado Cash dust attack on Sun's Ethereum address was a third-party attack (0.1 ETH sent unsolicited); his Aave account reinstated same day; this is NOT self-initiated mixer use. All deployer addresses show TronScan risk:false with no sanctioned contacts at 1-hop. No Chainalysis/TRM published report links any SUNSwap insider to DPRK/Lazarus cluster. No F-grade discretionary downgrade applies per

Sources #

Methodology #

Determine whether the deployer address has an on-chain path of ≤3 hops to a Chainalysis/OFAC DPRK-labeled cluster address.

See the full factor methodology and distribution across all protocols →