Does OFAC Apply to Crypto?

The direct answer on OFAC and crypto — including what it means for agent payments.

TL;DR

TL;DR: Yes. OFAC sanctions apply to crypto — wallets, tokens, and even smart-contract addresses (the Tornado Cash designations are the proof). Strict liability means intent does not matter.

The direct answer

OFAC has sanctioned specific crypto wallet addresses (947 in the SanctionsAI dataset, across EVM chains, Bitcoin, and Tron) and smart contracts. A US person — including a company deploying an agent — that processes a transaction with a sanctioned address commits a violation with civil penalties starting at $356,000.

What this means for agents

An agent that pays an invoice is the company acting. The screen must happen before the transaction is signed — protocols and rails (x402, AP2, AgentKit) do not screen for you.

The evidence

OFAC enforcement actions against crypto businesses (see the enforcement dataset) confirm the application of sanctions to crypto activity, including wallet designations and protocol-level actions.