For discussion before outreach
We will sell a Solana SDK that a wallet or protocol service integrates, so a user can send privately without leaving the product they already use.
We will not sell a contract to design Tornado Cash. This document is the sales approach. It is not a legal opinion, and no buyer is contacted until this approach is accepted.
What the buyer is purchasing
The buyer keeps the user, the wallet connection, and the signature. The SDK performs the private send underneath that signature.
| The buyer provides | The SDK provides |
|---|---|
| The account the user already trusts | The secret note for the amount sent |
| The prompt to connect and sign | The zero-knowledge proof that the note is unspent |
| The recipient and the amount | The relayer submission, so the recipient is not the signer |
A deposit address and a withdrawal address are not linked on-chain. An amount can be partial. What is not sent remains in a change note. This is the Veilix design already described in public and redeployed on Solana devnet.
Who we sell to
No wallet has agreed to integrate. Phantom and Solflare are the first accounts we intend to approach. They are not current customers.
Why a wallet would take the meeting
A person who wants a private transfer leaves the wallet, uses another site, and comes back. The wallet does not own the feature, and the user has to trust a second interface.
The same person stays in Phantom, Solflare, or the service they opened. That service signs. The SDK handles the note, the proof, and the relayer. Every integration shares one program and one anonymity set per asset.
The sale is to the team that distributes the wallet, not to the end user one transfer at a time.
The sales motion
Words we will use
If a buyer asks about Tornado Cash
Tornado Cash was sanctioned by the U.S. Treasury in August 2022. Treasury removed it from the sanctions list on March 21, 2025. Co-founder Roman Semenov remains sanctioned. In August 2025 a jury found Roman Storm guilty of conspiracy to operate an unlicensed money-transmitting business. The jury did not reach a verdict on the money-laundering and sanctions charges. Those charges are set for retrial on April 26, 2027.
One U.S. firm did pay the company that built Tornado Cash. In August 2020, Dragonfly Capital invested $882,000 in PepperSec, Inc. DL News reported that amount from a document shown at Storm’s trial. During the trial, prosecutors were reported to be considering charges tied to that investment. They later said in court that those reports were inaccurate, and that Dragonfly and its principals were not targets.
We have not found a U.S. company that commissioned Tornado Cash’s original development. Early work was the developers’ own, plus community funding, including about $31,200 in Gitcoin Grants Round 4 in January 2020. The Ethereum Foundation did not make that grant. Dragonfly’s investment came later.
How compliance sits inside the sale
Every integration blocks wallets flagged by a risk source such as Range. The check sits in the flow the SDK runs, so a flagged wallet does not enter a pool through our integration.
We will describe that control as a control. We will not describe it as permission. Tornado Cash added a compliance tool, and the criminal case still went forward. A buyer who needs a legal conclusion gets it from counsel, in writing, before payment.
Commercial shape
A withdrawal has three fees. Two are set. The wallet’s fee is not.
| Fee | Rate | Who receives it |
|---|---|---|
| Veilix protocol | 0.2% to 0.3% | The protocol |
| Veilix relayer | 0.3% | Whoever runs the relayer. Anyone may register and earn this. |
| Phantom, Solflare, or another Solana service | Not set. Illustrated below at 0.1% to 0.3%. | The wallet. It chooses the real rate. |
Before a wallet adds anything, the user pays 0.5% to 0.6%. Screening stays mandatory. The chain for a first trial stays devnet. An SDK support fee, if any, is still set with each buyer after legal review.
Economic feasibility
Phantom and Solflare already have the users. A private-send integration is feasible on fees alone only if a small share of those users actually send, and only if a lawyer allows the launch. If the launch is blocked, revenue is zero no matter how large the wallet is.
| What is published | What this model assumes | |
|---|---|---|
| Phantom reach | Almost 17 million monthly active users at the company’s stated peak | 17 million, used only as the base to multiply |
| Solflare reach | 4 million+ active users on the company site | 4 million |
| Share who send privately in a month | Not published | 0.05%, 0.20%, or 1.00% |
| Average send | Not published | $250 |
| Veilix protocol fee | 0.2% to 0.3%, supplied for this document | Used as the protocol’s revenue |
| Veilix relayer fee | 0.3%. Anyone may register and run a relayer. | A shared earning pool, not protocol revenue |
| Wallet fee | Not set. Phantom or Solflare will set it. | Illustrated at 0.1% to 0.3% of the same volume |
Sources: Phantom, “From Crypto Product to Finance Platform,” Brandon Millman. Solflare homepage, checked October 2026. Veilix rates supplied for this document. User counts below are illustrations, not a forecast, and the two wallets are not added together.
Already live on Solana
Both protocols are on Solana mainnet now. No public record found for this document shows OFAC listing either one, or a U.S. agency licensing either one. They are evidence that users already pay for private transfers on Solana. They are not evidence that a U.S. lawyer can skip the written review.
| Privacy Cash | Umbra | |
|---|---|---|
| Status | Live. Its own docs say more than $600 million privately transferred and swapped. | Live. Operated by Phoenix DAO LLC, a Marshall Islands company. |
| Published fee | Withdrawal: 0.35% plus 0.006 SOL per recipient. Deposit: none. | A protocol fee in basis points, set by governance and capped at 5%, plus a public relayer tip. The docs’ worked example uses 0.10% and labels it illustrative. |
| Screening | Deposits go through a relayer, which screens with CipherOwl. | Screens with Range. Private sends inside the pool are not the same check as funds leaving it. |
| Wallets | Tells users to withdraw to a new wallet such as Phantom or Solflare. | Its SDK connects to Phantom, Solflare, and other Wallet Standard wallets. The user opens Umbra. The wallet does not ship Umbra. |
Sources: privacycash.mintlify.app; docs.umbraprivacy.com fee model, updated 13 October 2026; app.umbraprivacy.com terms; sdk.umbraprivacy.com wallet adapters; Range, “Umbra integrates Range.” The $600 million figure is Privacy Cash’s own claim.
Economic feasibility
Each row is one wallet, alone. Protocol revenue uses 0.2% and 0.3%. The relayer column is the whole 0.3% pool for that volume. It is split among whoever has registered. What the wallet itself would earn is on the next page.
| Wallet and case | Sends / month | Volume / month | Protocol 0.2% | Protocol 0.3% | Relayer pool 0.3% |
|---|---|---|---|---|---|
| Phantom, 0.05% | 8,500 | $2.13 million | $4,250 | $6,375 | $6,375 |
| Phantom, 0.20% | 34,000 | $8.50 million | $17,000 | $25,500 | $25,500 |
| Phantom, 1.00% | 170,000 | $42.50 million | $85,000 | $127,500 | $127,500 |
| Solflare, 0.05% | 2,000 | $0.50 million | $1,000 | $1,500 | $1,500 |
| Solflare, 0.20% | 8,000 | $2.00 million | $4,000 | $6,000 | $6,000 |
| Solflare, 1.00% | 40,000 | $10.00 million | $20,000 | $30,000 | $30,000 |
Sends = reported users × assumed monthly share. Volume = sends × $250. Before any wallet fee, the user pays 0.5% to 0.6%. Privacy Cash publishes 0.35% plus 0.006 SOL.
Economic feasibility
These are the same sends and the same $250 average. The rate is a case, not a price the wallet has agreed. Another Solana service would earn 0.1% to 0.3% of whatever private-send volume starts in that service. No third user count is assumed here.
| Wallet and case | Volume / month | Wallet at 0.1% / month | Wallet at 0.3% / month | Wallet at 0.1%–0.3% / year |
|---|---|---|---|---|
| Phantom, 0.05% | $2.13 million | $2,125 | $6,375 | $25,500–$76,500 |
| Phantom, 0.20% | $8.50 million | $8,500 | $25,500 | $102,000–$306,000 |
| Phantom, 1.00% | $42.50 million | $42,500 | $127,500 | $510,000–$1,530,000 |
| Solflare, 0.05% | $0.50 million | $500 | $1,500 | $6,000–$18,000 |
| Solflare, 0.20% | $2.00 million | $2,000 | $6,000 | $24,000–$72,000 |
| Solflare, 1.00% | $10.00 million | $10,000 | $30,000 | $120,000–$360,000 |
On a $250 send the wallet keeps $0.25 at 0.1% and $0.75 at 0.3%. Added to the protocol fee and the relayer fee, the user then pays 0.6% to 0.9%.
Economic feasibility
Planning allowance for the first integration, not a quote and not a wallet’s price: $40,000–$80,000 for the written U.S. legal review, and $40,000–$80,000 to support the first engineering integration. The hurdle used below is $120,000, the middle of that range, for the first wallet only. A second wallet reuses the same opinion and most of the same SDK.
| Phantom, full year | Sends | Protocol at 0.2% | Protocol at 0.3% | Against a $120,000 hurdle |
|---|---|---|---|---|
| 0.05% of monthly actives | 102,000 | $51,000 | $76,500 | Does not cover |
| 0.20% of monthly actives | 408,000 | $204,000 | $306,000 | Covers, if the share is real |
On a $250 send the protocol keeps $0.50 to $0.75. The hurdle is 240,000 sends at 0.2%, or 160,000 sends at 0.3%. The relayer pool on the same Phantom year is $76,500 or $306,000, divided among registered relayers. Solflare at 0.20% returns $48,000 to $72,000 of protocol fees a year, so it pays the hurdle only after the first integration has already been paid for.
Economic feasibility
We will show a buyer this range. We will not show it as expected revenue, and we will not add Phantom and Solflare into one number. We will not say Privacy Cash or Umbra has been licensed by the United States.
Decision asked of the client
Devnet reference: test.veilixprotocol.com. Protocol description: veilix-protocol.pages.dev.