Overview

Fireblocks blocks outbound transactions to wallet addresses that are sanctioned by the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC). Fireblocks’ Legal and Compliance team subscribes to OFAC’s public Specially Designated Nationals (SDN) list updates and adds OFAC-sanctioned addresses to our backend systems to block outgoing transactions to those addresses.

You can familiarize yourself with OFAC’s sanctions program on OFAC’s FAQ page, including its 2022 guidance related to Tornado Cash. All sanctioned addresses linked to Tornado Cash are on OFAC’s SDN list and have been added to the Fireblocks backend system as blocked addresses.

Blocking of outgoing transfers to sanctioned addresses

When you submit a transfer request to a deposit address that is flagged on OFAC’s SDN list of sanctioned parties, Fireblocks will recognize the address from the corresponding list we update in our backend and automatically block the transfer.

The Fireblocks Policy Engine first checks your submitted transfer against the list in our backend, even before checking it against your Transaction Authorization Policy rules. You can read more about the transaction flow for outgoing transfers here.

When a transaction is blocked because the destination is a sanctioned deposit address, your transaction will fail. The reason for the failure message looks slightly different if you are using the Console or API.

When you attempt to transfer to a sanctioned address through the Fireblocks Console:

• In your transaction panel, the failed transaction will show:
  • Reason: Blocked by Policy

• In your transaction history, it will show:

  • Main status: BLOCKED

  • Sub-status: Blocked By Policy

When you attempt to transfer to a sanctioned address through Fireblocks API:

• The response of the transaction details at your relevant endpoint will show:
  • Status field: BLOCKED
  • subStatus field: BLOCKED_BY_POLICY

Blocking incoming transfers from sanctioned addresses

While it is not possible to prevent receiving an incoming transaction to your wallet due to the nature of the blockchain, you can take steps to remain compliant if you receive funds from a sanctioned address.

You can freeze funds received from sanctioned addresses or isolate them based on your internal compliance policies. Fireblocks recommends deploying a KYT/AML solution (we have native integrations with Chainalysis and Elliptic) that can automatically detect such high-risk transactions and take appropriate action based on your policies.

How can I check if an address is sanctioned by OFAC?

OFAC’s Specially Designated Nationals (SDN) database is public. You can download the latest list any time and search for an address.

LEGAL DISCLAIMER