For discussion before outreach

How we will sell Private Send

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

An integration, not a separate website

The buyer keeps the user, the wallet connection, and the signature. The SDK performs the private send underneath that signature.

The buyer providesThe SDK provides
The account the user already trustsThe secret note for the amount sent
The prompt to connect and signThe zero-knowledge proof that the note is unspent
The recipient and the amountThe 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

Wallets and Solana services, in that order

  1. 01Phantom, Solflare, and other Solana wallets. The user is already there. Private send should be a feature of that wallet, reached through the SDK.
  2. 02Other Solana protocol services that already initiate transfers: payment apps and protocol front ends with their own users.
  3. 03The devnet application, only as the place a buyer’s engineers try the flow. It is not the product we lead with.

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

The user should not have to leave

Without the SDK

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.

With the SDK

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

Five steps, and then a stop

  1. 1Send a one-page brief: what the SDK does, what the wallet still controls, and the devnet URL where their engineers can try a send.
  2. 2Walk through one devnet send. Deposit, partial withdraw, change note, relayer. No mainnet claims.
  3. 3Offer SDK access to their engineers, with screening required in the integration.
  4. 4Pause. Commercial terms are not signed until a U.S. lawyer has written the money-transmitter and sanctions points for that contract.
  5. 5Only then agree a price, a support scope, and a launch. Each wallet is a separate contract.

Words we will use

What we say, and what we do not say

We say

  • Non-custodial private send on Solana.
  • The wallet keeps the user and the signature.
  • Any amount, partial spend, change note.
  • Wallet screening is part of the integration.
  • Devnet is live for a technical trial.
  • A U.S. lawyer reviews the contract before anyone is paid.

We do not say

  • That the buyer is paying us to design Tornado Cash.
  • That a U.S. firm is currently offering to fund that work.
  • That screening is a legal shield.
  • That the August 2022 sanctions never happened.
  • That Roman Storm’s case had no verdict.
  • That Phantom, Solflare, or anyone else has already agreed.

If a buyer asks about Tornado Cash

The record we will give them

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

Screening is in the product we offer

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.

Until that writing exists, we can demonstrate devnet and discuss the SDK. We cannot take payment to build or launch the integration.

Commercial shape

Price is per wallet, and not set here

A withdrawal has three fees. Two are set. The wallet’s fee is not.

FeeRateWho receives it
Veilix protocol0.2% to 0.3%The protocol
Veilix relayer0.3%Whoever runs the relayer. Anyone may register and earn this.
Phantom, Solflare, or another Solana serviceNot 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

The user base is large enough. Use is the question.

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 publishedWhat this model assumes
Phantom reachAlmost 17 million monthly active users at the company’s stated peak17 million, used only as the base to multiply
Solflare reach4 million+ active users on the company site4 million
Share who send privately in a monthNot published0.05%, 0.20%, or 1.00%
Average sendNot published$250
Veilix protocol fee0.2% to 0.3%, supplied for this documentUsed as the protocol’s revenue
Veilix relayer fee0.3%. Anyone may register and run a relayer.A shared earning pool, not protocol revenue
Wallet feeNot 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

Privacy Cash and Umbra are running. That is not a U.S. license.

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 CashUmbra
StatusLive. Its own docs say more than $600 million privately transferred and swapped.Live. Operated by Phoenix DAO LLC, a Marshall Islands company.
Published feeWithdrawal: 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.
ScreeningDeposits 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.
WalletsTells 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

Protocol revenue, and the relayer pool beside it

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 caseSends / monthVolume / monthProtocol 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

What the wallet would earn at 0.1% to 0.3%

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 caseVolume / monthWallet at 0.1% / monthWallet at 0.3% / monthWallet 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

Year one covers the first integration only in the middle case

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 yearSendsProtocol at 0.2%Protocol at 0.3%Against a $120,000 hurdle
0.05% of monthly actives102,000$51,000$76,500Does not cover
0.20% of monthly actives408,000$204,000$306,000Covers, 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

What decides it

  1. 1Legal launch. A written opinion that blocks the integration ends the model. User count does not repair that.
  2. 2A wallet shipping it. Phantom’s reported reach is the stronger first case. Solflare is a second integration, not a separate business.
  3. 3The monthly share. At 0.20% of Phantom’s users, protocol revenue for the year is $204,000 to $306,000. At 0.05%, it is $51,000 to $76,500 and does not pay for the first integration.
  4. 4Who the 0.3% relayer fee pays. Anyone may register and run a relayer. That fee is their income, split across however many register. It is not Veilix revenue. At 0.1% to 0.3%, the middle Phantom case pays the wallet $102,000 to $306,000 a year. That is the wallet’s money.

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

Accept this approach, then we continue

  1. 1Confirm that the thing we sell is the Private Send SDK to wallets and Solana services.
  2. 2Confirm that screening is mandatory in every integration, and that it will not be described as a legal shield.
  3. 3Confirm that no outreach and no payment happen until a U.S. lawyer has written the money-transmitter and sanctions points.
  4. 4Confirm this fee schedule: protocol 0.2% to 0.3%, relayer 0.3% for anyone who registers, and a wallet illustration of 0.1% to 0.3% until that wallet sets its own rate. The user counts stay illustrations, not expected revenue.
  5. 5Confirm that Privacy Cash and Umbra are described as live Solana protocols with published screening and fees, not as a U.S. license.
  6. 6Name the first account we may contact, or hold the list.

Devnet reference: test.veilixprotocol.com. Protocol description: veilix-protocol.pages.dev.