Intermediate

Blacklist Proximity Explained

Why being "near" a blacklisted address matters—even if you're not blacklisted yourself

Being blacklisted is the obvious risk, but compliance teams look at something subtler: proximity. Even if your address is clean, receiving funds from an address that's "close" to blacklisted funds can trigger compliance reviews, exchange holds, or worse. Here's how it works.

What is proximity?

Proximity measures how many transactions separate your address from a blacklisted address. Think of it like degrees of separation:

đźš«
Blacklisted
Source of frozen funds
Sends USDT
1
1 Hop Away
Direct recipient
Sends USDT
2
2 Hops Away
Indirect recipient
Sends USDT
3
3+ Hops Away
Distant connection

The key insight: you might be 1 hop away from a blacklisted address and not know it. If someone sends you tokens, and their address gets blacklisted tomorrow, your proximity score changes retroactively.

Counting hops

Hops are counted by following the flow of funds:

0 Hops (Direct)

Your address IS the blacklisted address. Funds are frozen.

You

1 Hop

You received funds directly from a blacklisted address.

Blacklisted → You

2 Hops

You received funds from someone who received from a blacklisted address.

Blacklisted → Middleman → You

3+ Hops

Multiple intermediaries between you and the blacklisted address.

Blacklisted → ... → ... → You
Direction matters: Proximity typically looks at incoming funds. If you sent tokens TO a blacklisted address (before it was blacklisted), that's a different concern—you gave money to a bad actor, but you don't hold "tainted" funds.

Risk levels by proximity

Different hop counts carry different risk profiles:

Proximity Risk Level Typical Response
0 Hops Critical Funds frozen. Cannot transfer. Potential legal investigation.
1 Hop High Exchange account holds. Enhanced due diligence. Possible SAR filing.
2 Hops Medium Flagged for review. May require source of funds documentation.
3+ Hops Low Generally acceptable. Some conservative platforms may still flag.

Amount matters too

Receiving $10 from a 1-hop address is different from receiving $100,000. Most compliance systems consider both proximity AND amount when assessing risk. A small incidental transfer may be overlooked; a large one won't be.

Why compliance teams care

Proximity analysis exists because criminals try to "clean" funds by moving them through multiple wallets. By tracking hops, compliance teams can:

Trace fund flows

Follow where stolen or illicit funds ended up, even after multiple transfers.

Identify intermediaries

Find addresses that may be knowingly helping launder funds (mixing services, nested exchanges).

Protect platforms

Exchanges must demonstrate they're not processing criminal funds, even indirectly.

Regulatory compliance

AML regulations increasingly require looking beyond direct transactions.

Protecting yourself

You can't always prevent receiving "tainted" funds, but you can minimize risk:

1

Check addresses before transacting

Before accepting large payments, check the sender's address for blacklist status and proximity. If they're 1 hop from blacklisted funds, you'll become 2 hops.

2

Use fresh addresses for large receipts

Keep your main holdings in addresses that only receive from known, trusted sources. Use separate addresses for peer-to-peer trades or unknown counterparties.

3

Document your transactions

Keep records of who you transacted with and why. If flagged by an exchange, documentation proving legitimate business purpose can help resolve issues.

4

Monitor ongoing exposure

Addresses can be blacklisted retroactively. Set up monitoring to alert you if any of your past counterparties become blacklisted.

Eagle Virtual shows proximity: Our platform analyzes the transaction graph to show not just whether an address is blacklisted, but how many hops away it is from any blacklisted addresses—helping you assess risk before transacting.

Key takeaways

1
Proximity = transaction distance from blacklisted funds. Being 1 hop away means you received directly from a blacklisted address.
2
1-2 hops is high risk. Expect enhanced scrutiny, potential account holds, and compliance reviews at major exchanges.
3
Proximity changes retroactively. If someone you transacted with gets blacklisted tomorrow, your proximity score changes today.
4
Check before you transact. Verifying an address's proximity to blacklisted funds is the best protection against inheriting compliance risk.