Does OFAC apply to stablecoin lending?

Whether lending stablecoins to a borrower triggers US sanctions obligations.

TL;DR

TL;DR: Yes. Lending stablecoins to a blocked borrower, or accepting collateral from a blocked party, violates OFAC. Screen the borrower and any controlling owners before funding a stablecoin loan.

Stablecoin loans are transfers of value

A stablecoin loan moves value to a borrower, so it carries the same OFAC obligations as any other payment. The Office of Foreign Assets Control applies strict liability: a lender that funds a listed borrower can be penalized even without knowledge, and civil penalties start at $356,000 per violation. The token being a stablecoin changes nothing about that.

Borrower and collateral both matter

The 50 Percent Rule extends the block to entities 50 percent or more owned by a blocked person, which matters when the borrower is a company. Collateral is a second exposure: accepting a wallet or asset controlled by a blocked party can itself create liability, so both sides of the loan should be screened before funds move.

Screening before the loan funds

agentmail, the screening API at sanctionsai.dev, runs the check at approval: 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 or collateral source is stopped before the stablecoins leave, which is the only moment the decision is free.