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
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.
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.
Compare across platforms →"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
(1) REGULATORY LANDSCAPE: This provision directly engages OFAC regulations administered by the U.S.
Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.
Get the research letter
Companies change their terms quietly. We read every version and catch what actually changed. One email a week on the changes that matter and what they mean.
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.
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.
No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by OpenSea.