Does OFAC Apply to DAOs?

The direct answer on DAOs and sanctions.

TL;DR

TL;DR: Yes. The prohibition follows the transaction, not the org chart. A DAO treasury that pays or receives from a sanctioned wallet has executed a prohibited transaction - and the operators and signers remain in scope.

The exposure

Treasury outflows (vendor payments, grants, contributor compensation), inflows (donations, mints), and counterparty wallets are all in scope. The EtherDelta precedent put DeFi shapes on notice.

The honest note

Decentralization does not dissolve liability - the operators and signers behind the treasury carry the exposure. Screening is the layer that makes a treasury defensible.

The control

Screen every treasury transaction before it signs, fail closed, log everything. One sub-100 ms call per transaction.