Can OFAC sanction a smart contract?
Yes. OFAC has designated smart contract addresses as blocked property, with Tornado Cash as the precedent for US persons.
TL;DR
TL;DR: Yes. OFAC can designate a smart contract address on the SDN List, which prohibits US persons from transacting or interacting with it. Tornado Cash set that precedent.
The Tornado Cash precedent
OFAC designated Tornado Cash, a smart contract mixing service, and its associated addresses. That action showed that immutable smart contract code, not just people or companies, can be treated as blocked property. Once an address is listed, US persons generally must not transact with it, even when the interaction is fully automated.
What it means for agents
An agent that routes funds through a designated contract, or sends value to one, can trigger a violation for its operator under strict liability. Because contracts are interacted with by address, the practical control is to screen the target address before the agent acts. SanctionsAI checks a counterparty in one HTTP call under 100 ms and returns ALLOW for a clean address or BLOCK for a flagged one.
Why address-level screening matters
- Contract addresses are checked the same way as wallets against the SDN List.
- SanctionsAI syncs 947 OFAC-listed crypto wallets and 19,218 SDN names hourly, so newly designated contracts appear quickly.