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So... OFAC deploys a static analyzer scanning the address space for anything hosting a similar smart contract, then add that to the list.

You don't get it. Everyone says "OFAC may I <transaction info>?" OFAC implements services to take that info, and check it against their list and generate an answer real time. They can also update the list real time, and being centralized, every integrated processor starts giving that new entry the ol' deposit only treatment.

All OFAC needs is a scanner for what might be a hit, they preemptively add it to the list, do further digging in case it's a false positive, and still get the outcome they want. An effective brake on suspicious or possibly sanctioned individuals access to the financial network.

OFAC isn't stupid. They have the architecture of the financial network literally working for them in this case.

Decentralized doesn't mean squat with a fully public data structure that a centalized entity can real time declare chunks of off limits for a sufficiently large swathe of potential endpoints.

There is no penalty to a false positive by OFAC, or any of the service providers it oversees, btw. As that error case is handled by information collection and resubmission by the service provider to OFAC for re-analysis. The deck is stacked pretty much entirely in OFAC's favor.



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