Users can type in a name or paste a digital currency address. For addresses, the tool runs an exact-match search.

A positive result is a starting point, not a verdict. Names can overlap, and a match on a name still requires confirming you’re actually dealing with the listed party.

A negative result is arguably the trickier one. OFAC’s guidance makes clear that an address not appearing in the search does not mean it carries no risk. Wallets are cheap to create, and a sanctioned actor isn’t obligated to keep using the addresses the government already knows about.

Then there’s ownership. Under OFAC’s so-called 50% rule, ownership stakes tied to sanctioned parties can trigger compliance obligations even for an entity that never…