OFAC SDN list

OFAC SDN list (Specially Designated Nationals and Blocked Persons List) is the headline sanctions list maintained by the Office of Foreign Assets Control at the US Department of the Treasury. It contains individuals, companies, vessels, aircraft, and — since 2018 — specific crypto-asset addresses subject to US blocking sanctions. Any transaction or other dealing with parties on the list is prohibited for US persons (US citizens, residents, and US-organised entities), as well as for non-US persons relying on US payment rails.

Who and what ends up on the list

• individuals (terrorists, drug traffickers, human-rights violators, officials of sanctioned regimes);
• companies, banks, funds and affiliated structures (the “50% rule” — an entity 50% or more owned by an SDN is itself blocked);
• crypto addresses on public blockchains. Since 2018 OFAC has begun citing specific wallet addresses. As of 2026 the list covers Bitcoin, Ethereum, Tron addresses, with smaller presence on other networks.

In TON’s case, no individual TON-network addresses were on the SDN list at the time of writing — designations have so far targeted service operators whose front-ends may interact with TON.

Effect of designation

For US persons, an SDN designation of a counterparty means:

• immediate freezing of all assets within their control;
• prohibition of any new transactions;
• mandatory reporting to OFAC;
• penalties for evasion — up to hundreds of millions of dollars and criminal liability.

OFAC issues periodic General Licenses authorising specific categories of operations (humanitarian, legal-fee payments, permitted unwinds).

Crypto precedents

• 2018: the first crypto addresses (Iranian OTC desks) are added to SDN.
• 2020: addresses linked to North Korean hacker groups (Lazarus) are designated.
• 2022: Tornado Cash — for the first time a smart contract is sanctioned as such. This triggered the multi-year Van Loon v. Department of the Treasury case, in which courts ruled in 2024–2025 that “software as a person” cannot be sanctioned.
• 2023–2025: regular updates with addresses tied to mixers, ransomware operators, and OFAC-affiliated exchanges.

What this means for TON users

• Exchanges and wallets under US jurisdiction screen every transaction against SDN data (Chainalysis, TRM, Elliptic).
• Receiving funds from an SDN-tagged address can lead to a freeze of your exchange account.
• Self-custody wallets do not block by themselves, but address reputation may follow you into any centralized service later.

This is not legal advice; checking the status of a specific address is done via OFAC’s official data and specialised compliance tools.