OFAC sanctions penalties for crypto

Crypto-specific OFAC penalties have hit exchanges with large fines, and mixers have been designated as blocked entities.

TL;DR

TL;DR: Crypto businesses face the same strict-liability civil penalties as banks, starting at $356,000 per violation, and OFAC has also designated mixing services outright.

Exchange fines

Exchanges have been the most visible targets of OFAC enforcement in crypto. Because they process large transaction volumes, failures to screen against the SDN list have resulted in substantial civil penalties. The recurring theme in published settlements is that intent is not required: strict liability applies to crypto firms the same way it applies to banks.

Mixer designations

Mixers present a different pattern. Rather than only fining operators, OFAC has designated certain mixing services on the SDN list, which blocks US persons from transacting with them. The Tornado Cash designation is the most cited precedent, and it established that code and smart contracts can draw enforcement attention, not just the people behind them.

Individual and developer liability

Individual developers are not exempt. Where a developer's tool is used to move funds for a blocked person, the 50 Percent Rule and strict liability framework can still apply. Screening every wallet before a payment is the simplest control, and OFAC lists 947 crypto wallets today.

How to stay clear

The 50 Percent Rule is especially relevant in crypto, where ownership is often layered across entities and wallets. An address or entity owned 50% or more by a blocked person is itself blocked, even when the name on the transaction looks clean. Wallet-aware screening, not name matching alone, is what catches this.