OFAC digital asset sanctions practice (2018 to present)

OFAC digital-asset sanctions practice applies existing sanctions authorities to persons, property and transactions involving virtual currency. In November 2018 OFAC first published digital-currency addresses as identifiers associated with designated persons. An address is identifying information; it is not necessarily a separately designated legal person or a finding about every transaction touching it.

Practice and guidance

OFAC can designate a person under a programme, identify wallet addresses, block property, issue guidance and pursue civil enforcement. The Department of Justice can separately bring criminal charges or seize domains and assets under judicial process. A designation, civil settlement, charge, conviction, domain seizure and delisting have different legal effects.

OFAC's 2021 virtual-currency industry guidance remains current as at 30 July 2026. It emphasises risk assessment, screening, geolocation, transaction monitoring and reporting. Blockchain analytics platforms (Chainalysis, Elliptic, TRM) can support compliance, but their attribution is analytical evidence rather than an official adjudication.

Distinct actors and cases

A protocol, mixer, hosted wallet, exchange and address should not be collapsed. Treasury delisted Tornado Cash on 21 March 2025. The history is treated at United States designation and delisting of Tornado Cash (2022-2025) and Van Loon v Department of the Treasury (Fifth Circuit, 2024). The delisting does not create a universal bar on digital-asset sanctions.

The Department of Justice's Garantex action states allegations and charges concerning an exchange. Those claims should remain attributed and should not be treated as convictions unless adjudicated. Crypto exchanges as chokepoints (fiat on/off-ramps) explains why hosted services may be operationally important without making every exchange a state actor.

Current address data require publication-day checking.

Sources

1. United States Department of the Treasury, OFAC action of 28 November 2018.
2. United States Department of the Treasury, Virtual-currency industry guidance.
3. United States Department of the Treasury, Virtual-currency FAQs (accessed 30 July 2026).
4. United States Department of the Treasury, Tornado Cash delisting, 21 March 2025.
5. United States Department of Justice, Garantex action.