Question 1

When does OFAC apply to me?

Accepted Answer

OFAC sanctions apply to all US persons (citizens, permanent residents, entities organized under US law, and anyone physically present in the US) regardless of where the transaction takes place. They also apply extraterritorially to non-US persons engaging in transactions involving US persons, US-origin goods/services, or US dollars.

Question 2

What is strict-liability sanctions exposure?

Accepted Answer

OFAC enforcement operates on a strict-liability basis: intent does not matter. If you transact with a sanctioned party, even unknowingly, civil penalties of up to USD 381,000 per transaction (or twice the value, whichever is greater) apply. Documented screening is the primary defense.

Question 3

How often do sanctions lists update?

Accepted Answer

OFAC publishes SDN list updates daily. EU consolidated lists update on a comparable cadence. UK OFSI publishes updates weekly with intraday additions during active enforcement periods. A clean scan from last quarter is not a defense for a transaction this week.

Question 4

What about on-chain / crypto sanctions screening?

Accepted Answer

OFAC has designated specific crypto wallet addresses (Tornado Cash, Lazarus Group, etc.) and any interaction with them (direct or indirect through mixers) creates strict-liability exposure. On-chain screening checks counterparty addresses against OFAC SDN, plus transitive exposure via known mixer/sanctioned-cluster heuristics.

Do you need a sanctions scan?

Do your transactions or counterparties touch crypto on-chain activity, high-risk jurisdictions (Russia, Iran, North Korea, Venezuela, Cuba, Syria), or jurisdictions with material capital flows from sanctioned entities?