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How to Check Whether a Crypto Exchange or Wallet Is Subject to Sanctions

By Freedom251 Team · · 5 min read

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Check the exchange or wallet provider as a business and check each relevant blockchain address separately, using the sanctions lists and regulators that apply to your jurisdiction and transaction. An exact-match result in the U.S. Treasury’s OFAC address search is only one check: a no-hit does not establish that a provider, wallet, transaction, or connected address is clear.

What exactly should you check?

“Wallet” can mean a wallet service operated by a business or an address on a blockchain. Those are different things to screen. OFAC describes a hosted wallet provider as a business that creates and stores wallets for customers; such providers may also offer exchange or payment services. A wallet address, by contrast, is an alphanumeric identifier used as a possible destination for a transfer.

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  • Exchange or hosted-wallet provider: identify the legal entity operating the service, along with its trading names, aliases, and relevant subsidiaries.
  • Wallet address: copy the full address and identify its blockchain. Search every relevant address separately.
  • Transaction: consider the parties, destination and source addresses, and transaction context. A search of one address does not screen the entire transaction history or its counterparties.

OFAC’s FAQ 559, released October 15, 2021, discusses the distinctions between digital currency, wallets, wallet providers, and addresses.

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Which sanctions lists and rules apply?

Start with the jurisdictions connected to the people or businesses involved and to the transaction. Relevant connections can include where a person or business operates, where parties are located, and which legal regimes govern the transaction. An OFAC check is not a substitute for checking another applicable sanctions regime.

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For a business, check the relevant regulator’s register as well as sanctions lists. UK financial regulators’ joint March 2022 statement tells firms to check the FCA register or the equivalent register in the jurisdiction where a cryptoasset firm is based. A regulatory registration check and a sanctions-list search answer different questions: registration does not by itself establish sanctions status.

Jurisdiction example Sources and checks described by the authorities What to consider
United States OFAC’s Sanctions List Search and applicable OFAC lists, including the SDN List Use the exact address lookup for addresses; screen provider names and aliases separately. Potential blocking and reporting duties depend on the applicable rules.
United Kingdom Relevant UK sanctions lists and the FCA register, or the equivalent register where the cryptoasset firm is based UK financial regulators’ March 2022 statement describes screening customers and transactions and acting under applicable UK requirements.
Australia The Australian Sanctions Office (ASO) Consolidated List and Australian sanctions guidance DFAT’s digital currency exchange guidance, first published March 8, 2024 and updated July 28, 2026, discusses due diligence, transaction monitoring, and source- and destination-address checks.

These are examples, not a complete list of sanctions regimes or a determination of which law applies to a particular reader. Use the relevant authority’s current lists and guidance.

How to check a wallet address using OFAC’s search

  1. Confirm the address and network. Copy the complete address from a reliable source and verify which blockchain it belongs to. Addresses can be similar across networks, and a character or network error can invalidate the check.
  2. Open OFAC’s official Sanctions List Search. Enter the address hash in the ID # field. OFAC says this field uses exact matching, not fuzzy logic.
  3. Review any result against the underlying identifiers. Confirm that the address is the same and examine the listing details. A result should be treated as a lead for review, not as a complete legal determination.
  4. Search the provider and relevant parties separately. Use the legal business or person name and known aliases, and check the other applicable lists. Name searches should account for spelling variations; OFAC recommends fuzzy name matching as part of business screening.
  5. Record what you checked. For a business, retain the list and search method used, the date, the address and network, the names and aliases screened, and how alerts were reviewed. This supports repeat screening and escalation when lists or information change.

OFAC FAQs 562 and 594, dated March 19, 2018 and May 18, 2021 respectively, address digital currency address listings and search. OFAC’s October 2021 guidance for the virtual currency industry also describes screening and associated-address risk controls.

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What a search result does—and does not—tell you

If the address search finds a match

Check the listed identifying information and the context before concluding that the match is the same address or party. A similar name or an indirect blockchain connection alone does not establish a final legal match. For a real or plausible match, pause the transaction and use the compliance process that applies to you; a business should involve sanctions specialists or qualified counsel.

If the address search finds nothing

A no-hit means only that the exact address submitted was not found in that query. OFAC says its digital currency address listings are not likely to be exhaustive. The result does not clear the exchange or wallet provider, other addresses associated with it, a transaction’s counterparties, or the ownership and jurisdictional questions surrounding the activity.

If a third-party tool gives a risk score

Use a score as a prompt for investigation, not as an official sanctions decision. Verify the underlying identifiers and the applicable law. OFAC’s guidance discusses risk-based screening and blockchain analytics but does not certify a particular vendor or score.

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What businesses should add to a one-time lookup

For a business, screening is an ongoing control rather than a one-off search. OFAC’s October 2021 industry guidance recommends a risk-based compliance program that can include:

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  • Screening customer information at onboarding and screening relevant transactions and addresses.
  • Using name-matching methods that can catch spelling variations, rather than relying on a single exact spelling.
  • Rescreening as lists or customer information change, with a cadence suited to the business’s risk.
  • Reviewing relevant associated addresses and transaction history; blockchain analytics may help identify exposure, but alerts still require review.

These controls help identify potential exposure; they do not make a tool’s output a legal determination. OFAC’s guidance says it is explanatory, may change, and does not have the force of law or replace the authorities governing sanctions.

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What to do about a possible sanctions match

Do not move, release, or return potentially blocked property just because an automated check is inconclusive or a service provider recommends an action. Pause and escalate under the rules that apply to the parties and transaction. Review the identifiers, ownership, transaction context, and whether a relevant license or exception applies.

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For the U.S. context, OFAC FAQ 560 says U.S. persons must block property and interests in property of blocked persons and entities owned 50 percent or more in aggregate by blocked persons, subject to applicable authority, exceptions, and licenses. OFAC FAQ 646 says blocked virtual currency must be reported within 10 business days and annually while it remains blocked. These are U.S.-specific requirements, not universal deadlines or thresholds; confirm current rules and obtain jurisdiction-specific advice before acting.

UK and Australian requirements have their own legal tests and reporting channels. UK financial regulators’ statement describes freezing, not dealing with or making assets available where the relevant legal test applies, and reporting. Australian DFAT/ASO guidance describes freezing and reporting crypto held that is owned or controlled by a designated person, as well as due diligence and monitoring expectations for digital currency exchanges. Consult the relevant authority’s current guidance and use the appropriate compliance or legal process.

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complianceCrypto WalletscryptocurrencyOFACsanctions

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