How OFAC enforces crypto sanctions
OFAC enforces through strict liability, per-violation penalties, and designating specific wallet addresses.
TL;DR
TL;DR: OFAC enforces crypto sanctions through strict liability (intent is not required), civil penalties starting at $356,000 per violation, and direct designation of crypto wallet addresses, plus the 50 Percent Rule.
Strict liability
The defining feature of OFAC enforcement is strict liability. A business does not need to intend to violate a sanction, and it does not need to know a counterparty was blocked. Simply transacting with a designated party is enough to trigger exposure, which is why screening before the transaction matters more than after-the-fact explanations.
Penalties
Civil penalties start at $356,000 per violation. Because each transaction with a blocked party can be counted separately, the amounts can compound quickly. The exact final figure depends on the facts OFAC reviews, but the starting point alone is usually far larger than the cost of a screening subscription.
Tools of enforcement
- Designating wallet addresses: OFAC lists specific crypto addresses as blocked.
- The 50 Percent Rule: any entity 50 percent or more owned by a blocked person is also blocked.
- The SDN List: 19,218 names are published and updated, so designations change over time.
Because lists change, screening must be ongoing rather than one-time. sanctionsai.dev syncs its data hourly for exactly this reason.