Sanctions & Adverse-Media Name Screening

Draft for owner + counsel review — not legal advice. This document is an operational record. It does not replace a written legal memo, an OFAC determination, or any platform's compliance review. Engage qualified counsel before relying on any conclusion here. See DISCLAIMER.md.

Current status — CLEAR-WITH-CONDITIONS

G0-A sanctions and adverse-media status: CLEAR-WITH-CONDITIONS (counsel-adjudicated 2026-06-12, Anderson PC, matter ref HORMUZ-G0A-2026-06). Escalation history: REVIEW (2026-06-08) → REVIEW-HIGH (2026-06-09) → CLEAR-WITH-CONDITIONS (2026-06-12). Full record in §6.3.

What counsel cleared. Counsel found no OFAC nexus between the HORMUZ project and any sanctioned person, entity, or jurisdiction. Contract, treasury, and deployer returned zero interactive OFAC SDN + UN SC matches (F11–F14). The OFAC SDN name-level collision (F10 — 15 Iran-context HORMUZ/HORMOZ substring matches) is reputational / adverse-media exposure only, not a sanctions nexus attributable to HORMUZ-the-token. Counsel cleared pool launch and public marketing on Base subject to the conditions below.

Conditions (binding — see §6.3 §4). (1) Maintain MARKETING-RULES.md as written. (2) Keep site/compliance.html and this doc current; re-issue the affiliation notice on any material change. (3) Re-run interactive OFAC SDN name + address screening quarterly and before each CEX/aggregator submission. (4) Geo-restrict comprehensively sanctioned jurisdictions. (5) Maintain the explicit non-affiliation list.

Still gated — NOT cleared by this memo. Counsel did not opine on platform-specific CEX compliance, MiCA, or securities classification (G2 — separate, deferred). Aggregator and exchange submissions remain blocked by their own requirements (live trading data, audit, holder metrics) and require a pre-submission re-screen per condition (3). This memo unblocks G4 (pool launch) and public marketing only on the sanctions axis.

The HORMUZ name evokes the Strait of Hormuz and, by extension, Iran-related geopolitical and sanctions narratives. Centralized exchange and fintech compliance desks screen on names, narratives, traffic sources, on-chain flows, and adverse media. This document captures the affirmative facts, the public-record screening method, the counsel adjudication, and the conditions so that any later CEX or fintech compliance question can be answered from a single source.

Companion docs: LISTING-READINESS.md, LISTING-DATA-ROOM.md, MARKETING-RULES.md, DISCLAIMER.md.

Gate: G0-A. Status: CLEAR-WITH-CONDITIONS per the Anderson PC written memorandum dated 2026-06-12 (held privately with counsel; authorized summary in §6.3). Classification history: REVIEW (2026-06-08, §6) → REVIEW-HIGH (2026-06-09, §6.2) → CLEAR-WITH-CONDITIONS (2026-06-12, §6.3). Findings F1–F14 remain the permanent record; the classification reflects counsel's adjudication of those findings, not their deletion.

1. Affirmative facts about HORMUZ

These statements describe the project as it is operated. If any later becomes untrue, this file must be updated and a fresh compliance review run before any further submission.

Operators who can no longer attest to any of A1–A10 must escalate to G0-A review before further public-facing action.

2. Public-record screening checklist

This checklist must be re-run before each major external touchpoint (each CEX submission, each MM engagement, each significant PR placement, each quarter as routine hygiene). Record the run date and the outcome in LISTING-DATA-ROOM.md §6.

The result of each run is one of: CLEAN, REVIEW (one or more findings, owner + counsel must adjudicate before next submission), or HOLD (a finding that, on its face, would disqualify a submission — pause all platform activity until resolved).

6. First screening run — 2026-06-08

Classification: REVIEW. Surfacing findings that require owner + counsel adjudication before any platform submission proceeds.

What was checked

• WebSearch / WebFetch run on 2026-06-08 against publicly indexed material from treasury.gov, ofac.treasury.gov, gov.uk (UK Sanctions List), consilium.europa.eu, un.org, fincen.gov, and general adverse-media indices (Bloomberg, CoinDesk, The Block, Decrypt, Chainalysis, TRM Labs).
• Targets: name "HORMUZ", contract 0xf912a4A0c374a33f192d0657719cE107194573F1, treasury 0x8a5D41A03c40034Ec02a5e72450802b998F10f7F, deployer 0xBabc8aB5847F2e4960F995b92dA6A0812F9Ba54c.

Findings — name-level (HORMUZ)

Findings — address-level

Classification rationale

The contract, treasury, and deployer addresses are not surfaced as designated. The token itself is not a counterparty to any sanctioned entity. But the HORMUZ name carries elevated adverse-media exposure in the current 2026 news cycle, with active OFAC, EU, FinCEN, and press activity tying "Hormuz" + "crypto" to Iranian state actors, IRGC tolls, secondary sanctions, and an in-the-wild scam. Centralized exchange and fintech compliance desks pattern-match on names; a "HORMUZ" token applying right now will hit those stories first.

Per the rubric: this is REVIEW, not CLEAN. It is not HOLD because there is no direct linkage between HORMUZ-the-project and any sanctioned actor, but escalation to counsel before any aggregator or CEX submission is required.

Required next actions

1. Owner + counsel adjudication of findings F1–F7. Document the answer in §4 of this file as a resolved open item.
2. Manual interactive SDN/UK/EU/UN searches of the three addresses, captured as screenshots into LISTING-DATA-ROOM.md §7 private materials. Owner-driven; this agent's searches are indexed, not interactive.
3. Public-facing statement on the site distancing HORMUZ from the parallel scam, written so a CEX compliance desk reading hormuz.meme sees an unambiguous, contemporaneous disclaimer. Wording: HORMUZ is not affiliated with the Iranian government, the IRGC, the Persian Gulf Strait Authority, any shipping toll scheme, any reported impersonation scam, or any other party named in the 2026 Strait-of-Hormuz news cycle. Subordinate to MARKETING-RULES.md.
4. Marketing-rule reinforcement: explicit prohibition on any imagery, language, or framing that could be confused with the Strait-of-Hormuz toll narrative, the impersonation scam, IRGC iconography, Iranian flags, naval/tanker imagery, or any party to the active conflict. Already in §3 of this file; restate prominently on next site update.
5. Re-screen pre-G6 (CoinGecko submission) and again pre-G11 (Kraken submission), with the interactive SDN/UK/EU/UN searches performed each time.
6. Counsel scope expansion: ask the G2 Howey counsel whether they will also opine on the OFAC adverse-media exposure, or whether a separate sanctions counsel engagement is recommended.

Open items resolved against this run

None of the open items in §4 are resolved by this run — they remain open for counsel.

6.2 Second pass — manual interactive sanctions-portal screening — 2026-06-09

Classification escalated: REVIEW → REVIEW-HIGH. F1–F8 remain untouched and authoritative. F10 (logged below) is the basis for the escalation. This pass partially discharges the "manual interactive SDN/UK/EU/UN searches" follow-up from §6 → Required next actions item 2.

Method

Live browser navigation to the four official sanctions-portal interactive search forms, screen-target-by-screen-target, with the form fields populated by the project's identifiers. Results logged locally to screenshots/sanctions-private/ (a path inside .gitignore — not committed, owner-reviewable). The portals visited were:

• OFAC Sanctions List Search — https://sanctionssearch.ofac.treas.gov/
• UK Sanctions List Search — https://search-uk-sanctions-list.service.gov.uk/
• EU FSF (Financial Sanctions Database) — https://webgate.ec.europa.eu/fsd/fsf
• UN Security Council Consolidated List Search — https://search.sanctions.un.org/

Targets

• Project name: "HORMUZ" (also doubles as the symbol)
• Contract: 0xf912a4A0c374a33f192d0657719cE107194573F1
• Treasury: 0x8a5D41A03c40034Ec02a5e72450802b998F10f7F
• Deployer: 0xBabc8aB5847F2e4960F995b92dA6A0812F9Ba54c

Findings

Portals where the interactive search could not be completed

• UK Sanctions List Search (search-uk-sanctions-list.service.gov.uk) — the GOV.UK service returned its generic "Sorry, there is a problem with the service" error template at the time of this pass. No search interface available. Retry required at the next G0-A re-screen.
• EU FSF (webgate.ec.europa.eu/fsd/fsf) — requires authenticated EU Login (EU account or eID). Cannot be completed by the automation; should be routed through counsel during the G2 engagement, or alternatively by downloading and grepping the public consolidated XML at https://webgate.ec.europa.eu/fsd/fsf/public/files/xmlFullSanctionsList/content.

Updated classification rationale

The HORMUZ-the-token addresses (contract, treasury, deployer) are not surfaced on the interactive OFAC SDN search or the UN SC Consolidated List search. The name "HORMUZ" itself collides interactively with 15 Iran-context SDN entries on OFAC — confirming the F1 OFAC-alert-and-news-cycle finding at the live-portal level. The collision is not a designation of HORMUZ-the-token; it is a name-space overlap.

Classification escalated to REVIEW-HIGH because: - The interactive OFAC SDN name-screen hits (F10) move the project beyond an indexed-news-cycle concern into a confirmed live-portal collision space — exactly the surface a CEX compliance desk will run. - The address-level interactive verification is still partial (OFAC and UN complete; UK portal in outage; EU portal owner-only). - Counsel adjudication of F1–F7 plus F10 is still pending, and a commercial wallet-flow screen (Chainalysis / TRM / Elliptic) has not yet been run.

Specifically, REVIEW-HIGH is not weakened by F11–F14. Those address-level clean results were the expected outcome given that HORMUZ-the-token has no commercial nexus to any sanctioned party. What CEX compliance desks weight here is the name-level screen (F10) plus the news-cycle context (F1–F7). Both still require counsel sign-off before any aggregator or CEX submission.

REVIEW-HIGH is not HOLD: the project contract, treasury, and deployer returned zero hits at OFAC SDN and UN SC interactive searches, and HORMUZ-the-token is not itself designated. REVIEW-HIGH signals that the open-item set has grown beyond the original REVIEW posture and that the unblocking conditions are explicit (see the "Blocker" box at the top of this file).

Required next actions — updated

1. Owner + counsel adjudication of F1–F7 + F10. Still pending. F10 strengthens the case for counsel review rather than weakening it.
2. Manual interactive SDN/UK/EU/UN searches. OFAC + UN partial (this pass). UK pending portal recovery; EU pending owner or counsel-routed access. Once both are captured, this item closes.
3. Public-facing statement on the site. Done at G3 — see site/compliance.html and site/docs/sanctions-name-screening.html.
4. Marketing-rule reinforcement. Done at G3 — MARKETING-RULES.md §10.
5. Re-screen pre-G6 and pre-G11 with interactive searches at all four portals, including UK and EU.
6. Counsel scope expansion — still recommended; the F10 OFAC name-collision is exactly the kind of finding a Howey-only memo will not cover.

6.3 Counsel adjudication — Anderson PC memorandum — 2026-06-12

Classification: REVIEW-HIGH → CLEAR-WITH-CONDITIONS. F1–F14 are not deleted or softened; counsel adjudicated them and reached the conclusion below. The full memorandum is held privately with counsel; this is the authorized summary for the data room.

Provenance. This section records the project owner's representation of a written legal memorandum from the project's counsel. The full document is held with the firm; this summary is logged by reference so any reviewer can trace it to source. It is not an independent verification by the author of this file.

Engagement

Operative conclusion (verbatim — not rounded up)

"Based on the project facts provided, the interactive OFAC SDN and UN Security Council address-level screenings dated 2026-06-09, and the operator attestations in SANCTIONS-NAME-SCREENING.md §1 (A1–A10), counsel finds no OFAC nexus between the HORMUZ project and any sanctioned person, entity, or jurisdiction. The contract address (0xf912a4A0c374a33f192d0657719cE107194573F1), treasury (0x8a5D41A03c40034Ec02a5e72450802b998F10f7F), and deployer (0xBabc8aB5847F2e4960F995b92dA6A0812F9Ba54c) returned zero matches on interactive OFAC SDN and UN SC searches (findings F11–F14). The OFAC SDN name-level collision — 15 Iran-context HORMUZ/HORMOZ vessel and entity substring matches at fuzzy threshold 80 (finding F10) — is reputational and adverse-media exposure only, not a sanctions nexus attributable to HORMUZ-the-token, which is not itself a designated entry. HORMUZ-the-token is not affiliated with the IRGC, Persian Gulf Strait Authority, Iranian government entities, shipping authorities, toll schemes, or impersonation scams described in the 2026 news cycle (findings F1–F7). Counsel opines that the project may proceed with pool launch and public marketing on Base subject to the conditions in §4 below. Counsel does not opine on platform-specific CEX compliance, MiCA, or securities classification (G2 — separate engagement)."

Conditions attached (binding)

1. Maintain MARKETING-RULES.md as written — no profit / yield / return language, no geopolitical-hedge framing, no Iran / geopolitical imagery, no toll-collection or Strait-control taglines.
2. Keep site/compliance.html and this sanctions screening doc current — re-issue the affiliation notice on any material status change.
3. Re-run interactive OFAC SDN name + address screening quarterly and before each CEX/aggregator submission.
4. Geo-restrict comprehensively sanctioned jurisdictions (Cuba, Iran, North Korea, Syria, the so-called DPR / LPR, and the Crimea region of Ukraine) per MARKETING-RULES.md and site terms.
5. Do not claim affiliation with any government, shipping authority, or sanctioned entity; maintain the explicit non-affiliation list on the compliance page.

What this unblocks — and what it does NOT

Status of the original REVIEW-HIGH blocker conditions

The REVIEW-HIGH blocker listed four unblock conditions. Their status after this memo:

• UK Sanctions List check — not separately completed (portal was in outage). Counsel's opinion relied on OFAC SDN + UN SC interactive screens; counsel did not condition clearance on a UK interactive screen for pool launch / marketing. Recommend completing at the next quarterly re-screen and before any UK-facing distribution.
• EU sanctions check — not separately completed (FSF requires authenticated access). Same treatment; complete before EEA distribution.
• Commercial wallet screening (Chainalysis / TRM / Elliptic) — not run. Counsel did not condition pool-launch / marketing clearance on it. Recommend before the first CEX submission per the standing open item.
• Counsel adjudication — ✅ completed (this memo).

Net effect: the counsel-adjudication condition is satisfied and counsel's clearance is explicitly scoped to pool launch + public marketing. The UK / EU / commercial-wallet items move from "blockers" to pre-CEX-submission requirements carried in condition (3) and the open items.

6.4 Operational OFAC re-screen — 2026-07-14

This entry records an operational screening during the aggregator-listing campaign. It does not amend or extend counsel's 2026-06-12 opinion.

The five returned results are the score-100 subset of the 15 HORMUZ/HORMOZ/HOMA matches documented in the successful 2026-06-09 score-80 run (F10). Because the 2026-07-14 postback reset the input to 100 and omitted the score-94 and score-80 matches, do not describe this run as a reproducible score-80 screen. None of the five results was the HORMUZ token, a project wallet, or a project-controlled entity. The matches remain within the vessel/name-collision category already adjudicated by counsel; this operational log does not independently determine legal effect.

Condition (3) still requires a fresh interactive OFAC name-and-address screen before each aggregator or CEX submission. The name step must either return the complete score-80 result set or otherwise preserve evidence that the portal actually applied the requested threshold. CoinCodex was submitted earlier on 2026-07-14 before that control was reliably completed and is retained as a process exception in marketing/outbound/SUBMIT-HANDOFF-2026-07-14.md. Do not reuse this research-time result as the required action-time screen for another venue.

Enhanced-sensitivity control run

A second name-only control was completed later the same day at an actual portal threshold of 75, which is more sensitive than the required 80. The portal returned 18 results: the five score-100 vessel names above; seven score-94 HORMOZ/PERSIA HORMOZ vessel or company names; two score-80 HOMA results; and four lower-scoring HORAE/HORSE/HORNET results. This complete result set includes every match that the prior successful score-80 run was expected to surface. None was the HORMUZ token, a project wallet, or a project-controlled entity. The collisions remain in the name/vessel/company category previously adjudicated by counsel.

This validates the research-time screening control, but it is not a legal clearance and may not be reused as a venue's action-time screen. The five project addresses above returned 0 results in separate same-day address searches. Private screenshots are retained under the ignored screenshots/sanctions-private/ directory and must not be published or committed.

3. Marketing tie-in

The marketing surface is the most common source of unforced compliance error. The following must always be true on hormuz.meme, social profiles, GitHub, partner decks, and any other surface:

• No imagery of oil tankers, naval forces, maps emphasising the Strait, Iranian flags, IRGC iconography, or any party to a current armed conflict.
• No taglines invoking toll collection, "control the Strait", "tax the Strait", or any similar premise.
• No comparison to sanctioned entities or sanctioned tokens.
• No "geopolitical hedge" framing, no "war hedge" framing.
• No claim of association with any government or shipping authority.
• No copy implying HORMUZ supports, opposes, or funds any side of an active conflict.

Any non-compliant copy must be removed within 24 hours of discovery and the incident logged in LISTING-DATA-ROOM.md §6. See MARKETING-RULES.md for the full marketing rule set.

4. Open items for counsel review

These are explicitly out of scope for this draft and must be answered by qualified counsel before any CEX submission relies on them:

1. Is a separate U.S. OFAC compliance opinion needed in addition to the Howey memo (G2)? If yes, scope and counsel selection.
2. Does the HORMUZ name, considered with the immutable contract and the operator attestations above, present any OFAC nexus risk requiring an OFAC licence or self-disclosure?
3. Are there state-level (e.g., New York DFS) or non-U.S. (UK FCA financial promotions, EU MiCA Title II) name-based or narrative-based risks that should be addressed before EEA or UK distribution?
4. Should the project commission a wallet-flow analytics review (Chainalysis / TRM / Elliptic) before the first CEX submission, and at what cadence afterward?

Each open item gets an entry in the data room when answered.

7. Status