OFAC enforcement case studies

OFAC enforcement cases show a consistent pattern: unscreened transactions, strict liability, and penalties that start at $356,000.

TL;DR

TL;DR: The recurring lesson from OFAC cases is that unscreened payments get penalized under strict liability, regardless of intent, with civil penalties starting at $356,000 per violation.

The common fact pattern

Most public OFAC cases share a structure. A transaction touches a Specially Designated National or a blocked wallet, the institution did not screen it, and OFAC brings an action. Because the standard is strict liability, the absence of intent does not help the respondent, and penalties are calculated per violation, starting at $356,000.

The mixer precedent

The most consequential crypto case was the designation of Tornado Cash. OFAC added the mixer and its associated addresses to the SDN list, blocking US persons from interacting with it. The case demonstrated that code and infrastructure are in scope for sanctions, not only the people operating them, which changed how DeFi teams think about compliance.

The compliance lesson

The consistent lesson is that the control is cheap relative to the penalty. A screening call that returns ALLOW or BLOCK in under 100 ms, checking 19,218 SDN names and 947 OFAC-listed crypto wallets, prevents the transaction that becomes the next case study.

Reading the published cases

OFAC publishes its enforcement actions, and they are worth reading for the pattern they repeat. The same facts recur: a transaction that was not screened, a blocked counterparty, and a penalty that dwarfs the cost of a screening call. Studying them turns abstract rules into a concrete checklist for your own flow.