OFAC Dao FAQs
Answers to common questions about OFAC sanctions and DAOs, covering treasuries, proposals, and contributor payouts.
TL;DR
TL;DR: DAOs face the same OFAC exposure as any organization. Screen treasury transactions, proposal recipients, and contributor wallets before funds move.
Why DAOs are exposed
A DAO holds a treasury, passes proposals, and pays contributors through wallet addresses. OFAC applies strict liability, so a treasury payment to a designated wallet is a violation regardless of intent. The 50 Percent Rule also blocks entities a blocked person owns 50 percent or more, which can extend to a DAO's counterparties.
Common questions
- Which DAO transactions need screening? Treasury sends, proposal payouts, and contributor or grant payments.
- How is the check added? A single HTTP call before each payment, returning ALLOW or BLOCK in under 100 ms.
- What does the check cover? 947 OFAC-listed crypto wallets and 19,218 SDN names, synced hourly.