OFAC's Sanctions Search Isn't Permission: Unlisted Wallets Can Still Be Frozen

OFAC's free Sanctions List Search is a lookup, not a permission slip. Plug in a name or a crypto address and you might get a hit — but even a clean result doesn't make a transaction legal, per the Treasury office behind the tool. The search only covers what's printed on its lists, and blocking rules reach past what's printed.

Names and addresses don't behave the same way. Type a legal name into the Name field and you get approximate matches, ranked by a Minimum Name Score that measures text similarity — not the odds a company is sanctioned. A score of 100 returns exact matches only; lower it and the results widen, and OFAC declines to name one threshold that fits every search. Crypto addresses go into the ID # / Digital Currency Address field instead, and that search spits back exact matches only, character for character, so you compare the returned string against your counterparty's and check the currency label attached to it. OFAC's match guidance is blunt: a similar name, or even a shared street address, doesn't prove identity on its own.

The Nov. 6, 2026 designation notice shows how messy this gets. Treasury added eight Canadian money-services businesses to the SDN List, saying it designated them under Executive Order 13902 for operating in Iran's digital asset sector. Take Diverse Trade Inc., whose aliases include Million Exchange, Million Money Exchange and Millionex, with Canadian registration identifiers, locations, a website and a TRX-labeled digital currency address on the record. Searching the storefront brand instead of the legal name and aliases leaves you with far less to compare.

Here's the kicker: Cryptoyal appears as an alias for two separate companies, B Galaxy Inc. and CCC Inc., and their listed registration numbers differ. A familiar brand is not a unique legal identity. Addresses carry the same trap — keep the full string and its currency label together, because OFAC structures these identifiers as a Digital Currency Address, a currency symbol and the specific address.

Read the program column too, not just the name. The Canadian firms carry IRAN-EO13902, and Treasury's release lays out the basis for the designation and the blocking consequences that follow, with OFAC's Iran sanctions page linking the underlying authorities, guidance and licenses. OFAC also warns its published crypto addresses are unlikely to be exhaustive — meaning an unlisted wallet can still belong to a blocked person. Companies get the same treatment: under the 50 Percent Rule, an entity owned 50% or more, directly or indirectly and in aggregate, by blocked persons is itself blocked without its own SDN entry.

Two more things to tattoo on the wrist. The search tool excludes removed names and shows updated entries rather than historical versions, so a dated designation report documents a moment, not a permanent status. And OFAC states outright that using the tool doesn't replace due diligence or limit civil or criminal liability. A possible match means investigate — compare every available identifier and follow your compliance procedures, because the applicable rules decide whether property gets blocked, a transaction rejected, or an authorization lets it through.