To get ahead of the curve, some miners might voluntarily impose anti-money laundering measures on-chain, and there are some signs that this is already happening.

On Nov. 20, a pseudonymous bitcoin researcher who goes by 0xB10C published a blog post that said their mempool-monitoring tool spotted six bitcoin transactions that were not included in blocks by three major mining pools: ViaBTC, F2Pool and Foundry. All transactions involved addresses that OFAC had previously put on its sanctions list.