OFAC Bitcoin Compliance Guide Part 1
OFAC screening for Bitcoin payments, focusing on the listed wallets that an agent must check before paying.
TL;DR
TL;DR: Bitcoin addresses can be on OFAC's sanctions list, and sending BTC to a listed wallet is a strict liability violation. Screen the receiving address before the agent pays; clean wallets ALLOW and listed wallets BLOCK.
Why Bitcoin is screened
OFAC maintains a list of sanctioned crypto wallets alongside its SDN List of individuals and entities. Sending Bitcoin to a listed address violates sanctions even if the sender did not know. Intent is not required, and civil penalties start at $356,000 per violation.
How screening works
A screening API checks the receiving Bitcoin address against 947 OFAC-listed crypto wallets and 19,218 SDN names, synced hourly from US Treasury data. One HTTP call returns a decision in under 100 ms, so the check can run right before a transaction is signed and broadcast.
Practical guidance
- Screen the destination address before broadcasting.
- Use risk_score for addresses that need review.
- Start on the free tier, five checks per day, no key.