Can OFAC sanction open source code?

OFAC sanctions specific smart contract addresses, not source code, but code that facilitates sanctions evasion can still create legal exposure.

TL;DR

TL;DR: OFAC sanctions specific smart contract addresses, not open source code. But publishing or distributing code that facilitates sanctions evasion may carry legal exposure.

What OFAC actually designates

OFAC adds persons and specific addresses to the Specially Designated Nationals and Blocked Persons List, including 947 crypto wallets to date. Source code itself is not placed on the list. The designation targets the party who controls the address, not the code that deployed the contract or the repository where it lives.

Where exposure can still arise

Code is not neutral when it is built and promoted to evade sanctions. If a developer publishes a mixer or a bridge specifically designed to help designated parties move funds, that activity can be scrutinized as facilitation or evasion, even if the code itself is not designated. The 50 Percent Rule and strict liability also apply to services that transact with blocked parties, with penalties starting at over $350,000 per violation.

How to stay on the right side

• Screen counterparties, not just the code you ship.
• Do not tailor tools to evade OFAC designations.
• Use a screening API like sanctionsai.dev to check addresses in under 100 ms.

Open code is fine; open evasion is not.

The safest posture is to build and ship open code while screening the parties who use it, keeping the two questions separate.