OFAC vs EU vs UK: Which Sanctions List Actually Flags Your Wallet?

TL;DR - Screening only the OFAC SDN list misses sanctions designations unique to the UK and EU, so a clean OFAC check can still leave a sanctioned wallet undetected.

Your compliance policy says "screen against sanctions" and leaves it there, as though one government's blacklist covers every jurisdiction your business touches. It doesn't. The US, the UK, and the EU run 3 separate sanctions regimes, updated on 3 different schedules, and a wallet can clear one list while sitting flagged on another.

What's Actually on the OFAC SDN List?

OFAC's Specially Designated Nationals list is the default answer, and for good reason. It's the oldest and most enforced of the three regimes, carrying more than 17,000 entries across every US sanctions program, not just crypto. OFAC started designating individual cryptocurrency wallet addresses in 2018, and the list has grown fast since then. Plastron's own sanctions dataset currently tracks 780 OFAC-designated crypto addresses, part of a broader corpus of 3,901 labeled wallets spanning scams, hacks, mixers, and sanctioned exchanges. A hit here is unambiguous. US persons and any exchange with US touchpoints must block the transaction and freeze the funds. There's no gray area. But OFAC only covers what the US Treasury has formally designated, and it says nothing about who the UK or the EU consider sanctioned on their own lists. A compliance program built entirely around OFAC's SDN feed will pass every US audit and still miss a wallet that a UK regulator would flag on sight.

Does the EU Sanctions List Move on the Same Schedule as OFAC?

No. The EU Council updates its Consolidated Financial Sanctions List on its own timetable, independent of OFAC's designations, so a fresh OFAC entry can sit unmatched on the EU side for weeks. That gap matters for exchanges and DeFi front ends serving EU users under MiCA screening obligations, because a wallet clean on today's EU list can still carry OFAC exposure from a designation made the month before. The reverse happens too. The EU has sanctioned entities the US has not, most of them tied to Russia's war in Ukraine and its shadow banking network. A payment processor screening only OFAC would clear one of those addresses without ever knowing it sat on the EU's own blacklist. Miss one list, miss the rest.

Why Did the UK Just Merge Two Sanctions Lists?

Because running two lists side by side was creating gaps of its own, and UK regulators finally addressed it. Until January 28, 2026, the UK split its sanctions data across the UK Sanctions List (UKSL) and the Office of Financial Sanctions Implementation's separate Consolidated List of Asset Freeze Targets, and the two didn't always line up. From that date, UKSL became the single official source, folding financial-sanctions detail directly into the main list and retiring the old OFSI feed. The change came 5 months after OFSI demonstrated exactly why fragmentation was a problem: on August 20, 2025, it sanctioned Grinex, the ruble-token exchange that inherited Garantex's customer base, 6 days after OFAC had designated the same platform on August 14, 2025 under Executive Order 13694. A wallet that touched Grinex during that 6-day window was already OFAC-dirty and not yet UK-listed. Two governments, two clocks, one wallet caught in between. The joint comparative guidance OFAC and OFSI published in July 2026 acknowledges the mismatch, but it explains the two regimes side by side. It doesn't merge them.

Head-to-head

Checking these by hand means three separate lookups: OFAC's own sanctions search, the UK's UKSL search tool, and the EU's Consolidated List. Screening a wallet with Plastron runs all three checks against a single address at once, alongside mixer and stolen-funds exposure across Ethereum and six other chains. Here's what actually differs when you line the regimes up side by side.

Verdict

OFAC is the right starting point for almost every wallet screen, and it's the list Plastron checks by default. It's the largest of the three, the most consistently updated for crypto-specific designations, and the one most exchanges already build their compliance stack around. If your business only ever serves US-based counterparties with no EU or UK exposure, checking OFAC alone can genuinely be enough. That's the one case where the other two aren't required. Everyone else needs all three. One list isn't enough. A wallet can sit clean on OFAC and still carry an active EU Consolidated List or UKSL designation, and the 6-day gap that let a Grinex-linked wallet through UK screening in August 2025 shows exactly how that happens.

FAQ

Does OFAC share data with the UK and EU sanctions regimes?

Not automatically. OFAC and OFSI published joint comparative guidance on their two regimes in July 2026, but the underlying lists stay separate systems with separate update schedules. A designation on one does not create an entry on the other.

How often does the EU sanctions list update?

The EU Council sets its own schedule for the Consolidated Financial Sanctions List, and it isn't synchronized with OFAC or UK designation dates. New entries can land days or weeks apart from a matching US or UK action.

Can a wallet be sanctioned in the UK but not by OFAC?

Yes. The UK Sanctions List carries designations tied to UK-specific programs and enforcement priorities that don't always have a matching OFAC entry, and vice versa. Screening only one regime leaves the other's exposure invisible.

Do individuals need to check all three lists before a P2P or OTC trade?

There's no legal requirement for an individual outside a regulated VASP, but the exposure risk is real either way. Checking a counterparty's address against all three lists before sending funds is one of the few free steps that catches exposure a single-list check would miss.