By ยท ยท last updated 2026-08-08

The Three Crypto OFAC Settlements You Haven't Heard Of

EtherDelta ($450K), BitGo ($98K), BitPay ($507K) - the enforcement actions that defined DeFi, custody, and merchant payments. What each one teaches.

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Binance's $968M dominates the headlines, but the enforcement record that shaped crypto compliance is in the smaller cases. Three settlements defined the rules for DeFi, custody, and merchant payments.

EtherDelta ($450K, 2022): DeFi is not exempt

The first enforcement action against a DeFi platform. OFAC found EtherDelta failed to screen and processed transactions involving sanctioned users. The lesson: a protocol operator carries the obligation, and code does not waive it. Full case →

BitGo ($98K, 2021): custody is a rail

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BitGo's custody platform processed transactions for users in sanctioned jurisdictions. The lesson: the custody layer is one more rail where the screen must run first. Full case →

BitPay ($507K, 2021): merchant payments, same shape

BitPay processed merchant payments for users in embargoed regions. The lesson: a merchant payment path is the same shape as an agent payment path - geography screening catches what wallets and names miss. Full case →

The pattern

Every settlement traces to screening that did not run before transactions settled. The amounts scale with volume - which is exactly why agents need the screen in the payment path, not after it.

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