OFAC sanctions screening for crypto businesses
What the OFAC SDN list contains, why screening addresses matters, what a list check can and cannot catch, and what to do about a match. Not legal advice.
Updated 14 Sept 2026 · Advanced · 3 min read
In short
- The US Treasury’s Office of Foreign Assets Control (OFAC) publishes the Specially Designated Nationals (SDN) list, which has included cryptocurrency addresses since 2018.
- US persons generally may not deal with listed parties, and civil penalties can apply even without knowledge.
- Screening against listed addresses is the minimum, not complete protection: sanctioned groups control many unlisted addresses.
What the list is
OFAC, part of the US Department of the Treasury, administers US economic sanctions. Its best-known list is the Specially Designated Nationals and Blocked Persons (SDN) list: individuals, companies and groups whose property is blocked and with whom US persons generally may not deal.
Since November 2018 some SDN entries have included digital currency addresses. The first were two Bitcoin addresses linked to individuals connected with the SamSam ransomware. Addresses have since been listed on Bitcoin, Ethereum, Tron and other networks, attached to entries such as ransomware operators, darknet markets, state-linked hacking groups and sanctions-evasion networks.
Who needs to screen
US sanctions apply to “US persons” (US citizens and permanent residents, US companies and their branches, and anyone in the United States) and can reach others through the US financial system. Other jurisdictions run their own regimes, including the UK’s OFSI list and the EU’s consolidated list. Exchanges, payment processors, custodians and OTC desks are expected to screen, and increasingly so is any business that accepts crypto.
Civil penalties under OFAC’s regulations are based on strict liability: a business can be penalised for a prohibited transaction even if it did not know. What regulators weigh heavily is whether the business had a reasonable, risk-based compliance programme.
What address screening catches, and what it does not
- Direct matches: payments from or to an address on the list. This is the minimum every business should check, before crediting a deposit and before sending a withdrawal.
- Indirect exposure: funds that passed through listed addresses one or more hops earlier. An address report shows these links; how far back to look is a risk decision.
- Unlisted addresses of listed entities: sanctioned groups use far more addresses than are published. List screening cannot find them; behavioural and cluster analysis sometimes can.
Our sanctions screening tool checks an address against the digital currency addresses on the OFAC SDN list and shows its direct exposure. Paid plans add bulk screening and an API, so the check can run inside your own deposit and withdrawal flows.
If you get a match
- Stop. Do not complete the transaction, and do not tip off the counterparty.
- Confirm the match: the exact address, the network, and the SDN entry it belongs to.
- Block or reject as the rules require. Where property must be blocked (frozen), US persons must report the blocked property to OFAC within 10 business days.
- Record what you saw, what you decided and why.
- Take legal advice. This guide is general information, not legal advice.
Building a sensible programme
- Screen every deposit and withdrawal address automatically, not just the large ones.
- Keep evidence of each check: which list, when, and the result.
- Re-screen existing customers when the list changes. A clean address can become a listed one.
- Combine list screening with know-your-customer checks and transaction monitoring. The list is one control among several.