Checking a crypto wallet or exchange for sanctions exposure

What is listed, and what is not

OFAC publishes some digital-currency addresses on the SDN List, under the format "Digital Currency Address – [symbol]" followed by the address (OFAC FAQ 563). Addresses on the list belong to a blocked person; property in or involving them is blocked for US persons.

OFAC states that its digital-currency address listings are not likely to be exhaustive (FAQ 562). A wallet that is not on the list may still be controlled by a blocked person. The agency expects a US person who identifies such a wallet to block it and file a report (FAQ 646, FAQ 647).

The three checks, step by step

1. Search the wallet. Put the address into OFAC's Sanctions List Search with "Digital Currency Address" selected, and into the Consolidated Screening List. A match returns the SDN entry and the program.
2. Search the exchange or custodian. Run the legal name, trading names, any founder or executive name identified in the record, and any related address or jurisdiction. OFAC-designated venues on the record include SUEX OTC (designated 21 September 2021), Chatex, Garantex and the Tornado Cash smart-contract addresses — each with the official OFAC action behind the designation.
3. Apply the 50 Percent Rule. An entity 50% or more owned, directly or indirectly, by one or more blocked persons is itself blocked. OFAC FAQ 401 sets this out with worked examples. Map the exchange's beneficial ownership before you clear it.

OFAC's guidance on virtual currency

OFAC's Sanctions Compliance Guidance for the Virtual Currency Industry (15 October 2021) sets out what the agency expects of exchangers, administrators, miners, wallet providers and payment processors. It frames five components of a compliance programme: management commitment, risk assessment, internal controls, testing and auditing, and training. The guidance applies to US persons and to non-US persons who cause a US person to violate sanctions.

What a hit means, and what no hit means

A wallet on the SDN List is a blocked address: US persons may not transact with it, and must block property and interests in property held with it. A wallet that is not on the list is not clear by that fact: OFAC's listings are not exhaustive, and the 50 Percent Rule can block a counterparty whose address is not listed. Exchange counterparties follow the same logic as any other counterparty — see How to screen a counterparty against OFAC lists.

From an AI assistant

search_screening_lists on the Distributed Risk MCP server runs the Consolidated Screening List search on an address, a name or an identifier from Claude, ChatGPT or another MCP client. list_ofac_actions lists OFAC's recent actions and general licences, newest first. Both are read-only and need no key.

When the record is not enough

Blockchain analytics tools surface clustering, mixing and bridging that the sanctions lists do not describe. Where a wallet is linked to a transaction stream that passes through a mixer, a privacy coin or an unregistered exchange, brief an advisor and we arrange an investigation with a partner firm that works there.

Questions

Does OFAC list every blocked wallet? No. OFAC states its digital-currency listings are not likely to be exhaustive. Treat a non-match as a lead, not a clearance.

What about Tornado Cash? OFAC designated Tornado Cash and listed smart-contract addresses in August 2022; the designation was later lifted in March 2025. The current status is on OFAC's Recent Actions page. Check the record on the date of the transaction.

Is this legal advice? No. This page is a procedural checklist drawn from the public record.