Country Selection and OFAC Attestation

Why BlockReel Fund requires country selection and OFAC sanctions attestation at campaign creation and at every pledge.

Country Selection and OFAC Attestation

The legal compliance step that protects you and the platform.

When you create a campaign or pledge to one, you are asked to select your country and check a box attesting that you are not located in or controlled by a sanctioned party. This guide explains what that means, why it is required, and what happens if you misrepresent.

Jump To

1. What OFAC is 2. Which countries are sanctioned 3. What the attestation actually says 4. Why we ask, even on Solana 5. The three layers of enforcement 6. Citizenship vs residence 7. Travel and VPN considerations 8. Consequences of misrepresentation 9. Updating your country after a move

What OFAC is

The Office of Foreign Assets Control is a unit of the US Treasury Department. It administers and enforces economic sanctions programs against countries, regimes, terrorist organizations, narcotics traffickers, and other parties identified as threats to US national security or foreign policy.

Any US-incorporated entity (including BlockReel Inc., a Delaware corporation) is required to comply with OFAC. So is any platform that processes US-dollar payments through US banks. Stripe is a US company; their compliance flows directly through us. Solana itself is a global network, but US-incorporated platforms that use it are subject to the same OFAC rules.

Non-compliance is not a slap on the wrist. Penalties include civil fines up to $300,000+ per violation and, in severe cases, criminal charges. Platforms that ignore OFAC requirements get shut down.

Which countries are sanctioned

As of 2026, the comprehensive sanctions programs we enforce cover:

The list is updated periodically. We track OFAC's current Specially Designated Nationals (SDN) list and country sanctions programs and adjust accordingly. If your country is added or removed, you will see the change reflected in the campaign builder.

Sectoral and targeted sanctions also exist (e.g. against specific individuals in non-sanctioned countries). The wallet screening layer covers these.

What the attestation actually says

The exact text of the attestation checkbox at campaign creation:

> "I confirm that I am not a resident of, located in, or organized under the laws of a country or region subject to comprehensive US sanctions (Cuba, Iran, North Korea, Syria, or Russia). I am not on the OFAC Specially Designated Nationals list or any equivalent restricted-parties list. My payout account (Stripe and/or Solana wallet) is not held by a sanctioned party. I understand that misrepresentation may result in account termination, fund freeze, and reporting to relevant authorities."

At pledge time, backers see a similar attestation focused on the pledge transaction.

Checking the box is treated as a legal certification, not a casual click-through. The timestamp is recorded with your IP and account ID for audit purposes.

Why we ask, even on Solana

A reasonable question: if Solana is pseudonymous and permissionless, why does BlockReel ask sanctioned parties to attest that they are not?

Two answers:

1. We have a legal obligation regardless of the rail. Our LLC must screen counterparties to the extent practical. A self-attestation is a reasonable, industry-standard step even when perfect verification is impossible. 2. It establishes intent. If a sanctioned party lies to access the platform, the legal posture is clear: they committed fraud against us, and we acted in good faith based on their representation. We are not exposed to the same liability as if we had no screening process at all.

This is the same standard used by Coinbase, Circle (the USDC issuer), and every other major crypto platform that operates in the US.

The three layers of enforcement

Self-attestation is the first layer. Two more layers run automatically:

Layer 2: IP-level geoblocking. Cloudflare detects the visitor's country at the network edge and blocks loading of /fund/* routes from sanctioned countries. The response is HTTP 451 (Unavailable for Legal Reasons). Users in sanctioned countries cannot even see the campaign page.

Layer 3: Wallet screening. For Solana pledges, the pledging wallet is checked against an on-chain sanctions oracle (Chainalysis or equivalent). If the wallet is flagged or has interacted with flagged wallets in a way that triggers our policy, the pledge is rejected before submission to the network. Creator payout wallets are screened at the time of wallet connection.

All three layers operate independently. A user determined to circumvent one might get past it (e.g. VPN can mask IP); the others still catch most cases. The combination is what satisfies the "reasonable, risk-based effort" standard OFAC requires.

Citizenship vs residence

The attestation is about residence, not citizenship. If you are a citizen of a sanctioned country but reside legally in a non-sanctioned country with a non-sanctioned bank account or wallet, you can participate.

Example: a Russian citizen with a German residence permit, a German bank account, and a wallet held in their name in Germany is eligible. The attestation should reflect Germany as the country of residence and the country of the payout account.

A US citizen residing in Iran is not eligible, regardless of citizenship, because the comprehensive Iran sanctions block US persons from financial transactions in Iran.

Travel and VPN considerations

If you are traveling temporarily through a sanctioned country, you cannot pledge from there. The IP geoblock will catch you. Wait until you are back in a non-sanctioned country.

Using a VPN to mask your location while in a sanctioned country violates the attestation. You are certifying your actual physical location, not your apparent location. If we later detect evidence of VPN-based circumvention (mismatch between attestation and other signals, on-chain history, account behavior), we will close the account.

If you legitimately move between non-sanctioned countries (e.g. an American working in Berlin for a year), your residence at the time of attestation is what matters. Update it if it changes substantively.

Consequences of misrepresentation

If we discover that a creator or backer falsely attested:

We do not enjoy doing this. We do it because the alternative is platform-level liability that would shut Fund down for everyone.

Updating your country after a move

If you move from one non-sanctioned country to another during a campaign, update your country in account settings. The campaign attestation reflects the country at the moment of attestation; ongoing residence is reflected in your account profile.

If you move into a sanctioned country mid-campaign, contact admin immediately. We will work with you to wind down the campaign cleanly (existing pledges processed normally, no new pledges accepted, payouts handled according to where the campaign was launched from).

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Next: Adding Team Members and Collaborators covers how to credit your team on the campaign page.