# Sanctions exposure

Working definition: how closely an address or flow of funds is linked to sanctioned persons or blocked property.

Canonical: https://achivx.org/glossary/sanctions-exposure/
Updated: 2026-11-01

Sanctions exposure (working definition) describes how closely a person, address or flow of funds is connected to sanctioned persons or blocked property. OFAC says US persons must block the property of persons on the SDN List and of entities owned 50 percent or more by blocked persons, whether a transaction is in digital or fiat currency. Its address listings are not likely to be exhaustive, and it asks holders of wallets associated with an SDN to block them and report. Tether's terms use the same 50 percent test.

## What the sources say

| Source | Quote | Link |
|---|---|---|
| OFAC FAQ 560: same obligations for digital currency | "Yes, the obligations are the same. U.S. persons (and persons otherwise subject to OFAC jurisdiction) must ensure that they block the property and interests in property of persons named on OFAC’s SDN List or any entity owned in the aggregate, directly or indirectly, 50 percent or more by one or more blocked persons" | [ofac.treasury.gov](https://ofac.treasury.gov/faqs/topic/1626) |
| OFAC FAQ 562: listings not exhaustive; block and report | "OFAC’s digital currency address listings are not likely to be exhaustive. Parties who identify digital currency identifiers or wallets that they believe are owned by, or otherwise associated with, an SDN and hold such property should take the necessary steps to block the relevant digital currency and file a report with OFAC" | [ofac.treasury.gov](https://ofac.treasury.gov/faqs/topic/1626) |
| Tether terms: Sanctioned Person 50 per cent test | "(ii) directly or indirectly owned 50 per cent or more by any Person or group of Persons in the aggregate, or a Digital Tokens Wallet associated with such Person or Persons, referred to in any Sanctions List" | [tether.to](https://tether.to/en/legal/) |

## Note on sources

No official definition of "sanctions exposure" was found. The first sentence above is a working definition; the rest follows OFAC's and Tether's own wording.

## Related terms

- [OFAC SDN list](/glossary/ofac-sdn-list/)
- [Freeze (address freeze)](/glossary/freeze/)
- [Blacklist (issuer blacklist)](/glossary/blacklist/)

## See also

- Explainer: [What is sanctions exposure, and how is it different from being sanctioned?](https://achivx.com/academy/how-it-works/what-is-sanctions-exposure.html)
- Review: [revain.org/coins/usdt/](https://revain.org/coins/usdt/)
- Review: [revain.org/coins/usdc/](https://revain.org/coins/usdc/)

Checked against the sources on 2026-11-01.

## revain.org
- https://revain.org/coins/usdt/
- https://revain.org/coins/usdc/

## Sources
- https://ofac.treasury.gov/faqs/topic/1626
- https://tether.to/en/legal/