EU Crypto Sanctions: Which Addresses Are on the List and How to Screen Them

If you search for a "EU crypto sanctions list" expecting a downloadable file of Ethereum and Bitcoin addresses, you will not find one. The EU Consolidated Financial Sanctions List — maintained by the European External Action Service (EEAS) — lists sanctioned individuals and entities by name, date of birth, and identification number. It does not contain cryptocurrency wallet addresses.

This creates a practical problem for compliance teams working in Europe: how do you screen crypto transactions against EU sanctions if there is no EU crypto address list?

How EU Sanctions Apply to Crypto

EU sanctions are directly applicable law in all member states under Council Regulations. When an individual or entity is added to the EU Consolidated List, it becomes illegal for anyone within EU jurisdiction to:

• Make funds or economic resources available to that person or entity
• Transfer assets to or from accounts they control
• Facilitate transactions that benefit a sanctioned party

This applies to crypto assets. A CASP transferring Bitcoin to a wallet controlled by a sanctioned individual is in breach of EU sanctions law, regardless of whether that specific wallet address appears in any official list.

The challenge is identification: the EU list gives you a name and sometimes a passport number. It does not tell you which blockchain addresses that person controls.

Where the Crypto Addresses Actually Come From

The primary source of sanctioned crypto addresses for EU compliance purposes is the OFAC SDN List published by the US Treasury. OFAC has been systematically adding cryptocurrency addresses since 2018, tagging each one with the chain (ETH, BTC, TRX, etc.) and the digital currency identifier (XBT for Bitcoin, ETH for Ethereum, and so on).

When OFAC sanctions a crypto entity or individual, it typically publishes the associated wallet addresses as part of the SDN entry. These are the addresses that compliance teams screen against.

The OFAC list currently contains over 780 crypto addresses associated with sanctioned entities across programmes including SDGT (counter-terrorism), DPRK3 (North Korea/Lazarus Group), CYBER2 (malicious cyber activity), and IRAN (Iran sanctions).

UK OFSI also publishes a sanctions list that includes crypto addresses, currently containing around 15 addresses. These are largely aligned with OFAC designations but are maintained independently by HM Treasury.

Why EU Compliance Teams Still Need to Screen Against OFAC

For a CASP or financial institution operating in the EU, screening against OFAC may seem optional — OFAC is a US authority and its primary jurisdiction is US persons and entities. However, there are several reasons EU compliance programmes routinely screen against OFAC:

Secondary sanctions risk. Transactions involving OFAC-designated parties can trigger secondary sanctions exposure for non-US entities, particularly in sectors dealing with US correspondent banks.

Best practice alignment. The FATF and EBA both recommend cross-jurisdictional sanctions screening. EU supervisors increasingly expect compliance programmes to cover major international lists, not just the EU list.

Factual overlap. Many OFAC-designated crypto entities are also subject to EU asset freeze measures by name — the Lazarus Group, Hamas-affiliated entities, and Russian cybercrime groups appear on both lists. Screening OFAC addresses is an efficient proxy for identifying EU-sanctioned crypto actors.

MiCA requirements. Under MiCA, CASPs must implement effective AML and sanctions compliance programmes. Regulators expect this to include screening against relevant international sanctions lists, not only the EU consolidated list.

How to Screen Crypto Addresses for EU Compliance

Given that the EU list does not contain crypto addresses, an effective screening programme combines three layers:

Layer 1 — Address screening against OFAC and UK lists. Screen every wallet address involved in a transaction against OFAC SDN and UK OFSI lists. This catches the majority of sanctioned crypto addresses in circulation.

Layer 2 — Entity name screening. Screen counterparty names against the EU Consolidated List, OFAC, and UK OFSI by entity name. This catches cases where the wallet address is not yet listed but the controlling entity is sanctioned.

Layer 3 — Indirect exposure analysis. Check whether a wallet has interacted with known sanctioned addresses or mixing services. A wallet that received funds from a Tornado Cash pool two transactions ago may be carrying tainted funds even if it is not directly listed.

AMLRadar covers all three layers. The Wallet Screener checks any crypto address against OFAC, EU (where applicable), and UK lists in real time with a risk score from 0 to 100. The Entity Screener searches sanctioned entity names across all three lists with exact, partial, and fuzzy matching. Indirect mixer exposure is detected by analysing on-chain transaction history.

The Gap in the EU Framework

The absence of crypto addresses from the EU Consolidated List is a known gap in the EU sanctions framework. The EEAS has acknowledged that the current format of the list was not designed with digital assets in mind.

This gap is expected to narrow under the AMLA framework. The Anti-Money Laundering Authority, which takes on direct supervisory responsibilities from 2028, has indicated that technical standards for crypto-specific sanctions compliance — including address-level screening — will be part of its regulatory package. Draft regulatory technical standards published in 2025 suggest that AMLA will require CASPs to maintain address-level sanctions screening capabilities and to cross-reference EU designations with international lists where EU-specific address data is unavailable.

Until then, best practice for EU-based compliance teams is to treat OFAC and UK OFSI address lists as the de facto standard for crypto address screening, supplemented by entity-level checks against the EU Consolidated List.

Practical Checklist for EU Crypto Sanctions Compliance

For compliance teams building or reviewing their crypto screening programme:

• Screen all transaction addresses against OFAC SDN and UK OFSI before settlement
• Screen counterparty entity names against EU Consolidated List, OFAC, and UK OFSI
• Check for indirect exposure to sanctioned addresses in transaction history (at minimum 2 hops)
• Document every screening check with timestamp and result for audit purposes
• Update your screening database at least every 24 hours — sanctions can be added at any time
• Flag any match, including partial name matches, for manual review before proceeding

For the instant payments context: the EU Instant Payments Regulation requires screening to complete within 10 seconds. Any manual review process must be triggered only for flagged transactions, not applied to every payment.

AMLRadar's screening methodology explains exactly how each check works, what confidence level is assigned to each result, and what the risk score components mean. All results include a timestamp and source attribution suitable for compliance documentation.