OFAC and crypto lending

Whether OFAC sanctions rules apply when a platform lends crypto to a borrower.

TL;DR

TL;DR: Yes. Lending crypto to a blocked person or against collateral tied to a blocked party is a violation of OFAC, and intent is not required. Screen the borrower and any controlling owners before funding a loan.

Lending is a transfer of value

A crypto loan moves funds from a lender to a borrower, so it falls under the same sanctions rules as any payment. The Office of Foreign Assets Control (OFAC) is a strict liability regime: a platform that lends to a listed borrower can be penalized even if it did not know. Civil penalties start at $356,000 per violation.

The 50 Percent Rule and collateral

The 50 Percent Rule extends the block to any entity 50 percent or more owned by a blocked person, which matters when the borrower is a company rather than an individual. Collateral also deserves attention: accepting a wallet or asset controlled by a blocked party can itself create exposure, so both the borrower and the collateral source should be screened.

A check before the loan funds

agentmail, the screening API at sanctionsai.dev, runs the check at the moment a loan is approved: one HTTP call under 100 ms returns clean (ALLOW) or flagged (BLOCK), using 947 OFAC-listed crypto wallets and 19,218 SDN names synced hourly. A flagged borrower is stopped before funds move, which is the only point where the decision is cheap.