Provision record
OpenSea · OpenSea Terms of Service · View original document ↗

OFAC Sanctions User Representations

Medium severity High confidence Explicit document language Unique · 0 of 352 platforms
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Document Record

What it is

Users represent and warrant that they are not located in, resident in, or organized under the laws of a U.S.-sanctioned country, are not subject to government or UN sanctions, and are not owned or controlled by sanctioned persons or entities, and these representations must remain true for the duration of Platform use.

This analysis describes what OpenSea's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision places affirmative compliance representations on users regarding OFAC sanctions status, extending to indirect ownership, control, and transaction counterparties. The agreement states that these representations must remain continuously true throughout the user's Platform engagement, and OpenSea reserves the right to restrict or disable Accounts for failure to provide compliance documentation.

Clause Stability Stable

0
Changes
4
Months Monitored
Jul 9, 2026
First Seen
Jul 9, 2026
Last Seen

Consumer impact (what this means for users)

Under this clause, users affirmatively represent compliance with OFAC and other government sanctions regimes as a condition of Platform access, including representations about their officers, directors, shareholders, and transaction counterparties. OpenSea may restrict or permanently disable Accounts if requested documentation is not provided.

Cross-platform context

See how other platforms handle OFAC Sanctions User Representations and similar clauses.

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▸ View Original Clause Language DOCUMENT RECORD
"
By using the Platform, you represent and warrant that you will comply with all applicable laws, including local, state, federal, and international regulations. You agree not to use the Platform, or otherwise enable access to the Platform, if: You are located in, ordinarily resident in, or organized under the laws of a U.S.-sanctioned country. You are subject to sanctions imposed by the U.S. Government, any other government, or the United Nations. You are owned or controlled, directly or indirectly, by any person or entity subject to sanctions or located in, ordinarily resident in, or organized under the laws of a U.S.-sanctioned country.

Excerpt from OpenSea's Terms of Service

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

(1) REGULATORY LANDSCAPE: This provision directly engages OFAC regulations administered by the U.S.

Insight

Unlock the full institutional analysis

Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →

Provision details

Document information
Document
OpenSea Terms of Service
Entity
OpenSea
Document last updated
May 5, 2026
Tracking information
First tracked
July 9, 2026
Last verified
July 9, 2026
Record ID
CA-P-014744
Document ID
CA-D-00209
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
76b04082fc896790748950b58f45fa27b32b077fa7f68023f3882c090ed2ad1f
Analysis generated
July 9, 2026 06:20 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: OpenSea
Document: OpenSea Terms of Service
Record ID: CA-P-014744
Captured: 2026-07-09 06:20:04 UTC
SHA-256: 76b04082fc896790…
URL: https://conductatlas.com/platform/opensea/opensea-terms-of-service/provision/CA-P-014744/ofac-sanctions-user-representations/
Accessed: Sept. 9, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does OpenSea's OFAC Sanctions User Representations clause do?

This provision places affirmative compliance representations on users regarding OFAC sanctions status, extending to indirect ownership, control, and transaction counterparties. The agreement states that these representations must remain continuously true throughout the user's Platform engagement, and OpenSea reserves the right to restrict or disable Accounts for failure to provide compliance documentation.

How does this clause affect you?

Under this clause, users affirmatively represent compliance with OFAC and other government sanctions regimes as a condition of Platform access, including representations about their officers, directors, shareholders, and transaction counterparties. OpenSea may restrict or permanently disable Accounts if requested documentation is not provided.

Is ConductAtlas affiliated with OpenSea?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by OpenSea.