As per our review, Lombard’s Terms are drafted to permit Lombard to implement and enforce mixer-related compliance controls based on risk signals alone, without needing to establish that a user “actually used” a mixer. The breadth of the “Prohibited Uses” construct provides Lombard with strong contractual discretion to treat mixer exposure as an AML/sanctions risk-management trigger. Practically, however, any such measures are constrained to what Lombard controls (i.e., the front-end and Lombard-operated features) and cannot extend to altering or reversing the underlying on-chain protocol state.
Disclaimer
This review was independently prepared by LlamaRisk, a DeFi risk service provider funded in part by the Aave DAO. LlamaRisk is not directly affiliated with the protocol(s) reviewed in this assessment and did not receive any compensation from the protocol(s) or their affiliated entities for this work. The information provided should not be construed as legal, financial, tax, or professional advice.