Does OFAC apply to gaming and crypto?

Yes. Play-to-earn games, gaming NFTs, and in-game crypto economies all fall within OFAC's scope.

TL;DR

TL;DR: Yes. When a game lets players earn, trade, or withdraw crypto and NFTs, those value transfers are subject to OFAC, and the studio must screen player wallets.

When a game enters scope

OFAC reaches value transfers, not just traditional payments. A game enters scope when it has any of these:

• Play-to-earn rewards paid in tokens.
• Tradable NFTs with real value.
• An in-game economy where assets can be cashed out.

What to do

Screen player wallets against the SDN List before paying rewards, settling trades, or processing withdrawals. OFAC applies strict liability, so the studio does not need intent when a sanctioned wallet receives value. A game that lets players cash out is, in effect, a payments business.

Practical controls

Run a screening call under 100 ms inside the reward and marketplace flows so gameplay feels unchanged. Log every screen, and block flagged wallets. Apply the 50 Percent Rule to majority owned entities.

What makes a game a payments business

The line is whether value leaves the game. A purely cosmetic item that cannot be sold stays outside sanctions scope, but the moment a player can cash out tokens or sell an NFT, the studio is moving value and inherits the obligations of a payments business. If you are unsure, assume the economy is in scope and screen it. That assumption is cheap: a fast screen adds no friction to gameplay, while a missed payout to a sanctioned wallet can cost far more.