Crypto Exchange OFAC Compliance Checklist [2026]

Crypto exchanges face some of the most significant OFAC enforcement exposure in the industry. This checklist covers the screening controls OFAC expects at each stage of the exchange workflow.

Section 1: Onboarding

• KYC/KYB process includes OFAC screening against full SDN list
• Beneficial ownership screening for corporate accounts (50% Rule applied)
• Jurisdictional screening — onboarding rejected for comprehensively sanctioned countries
• IP address screening — access blocked from sanctioned jurisdictions

Section 2: Transaction Screening

• Every deposit wallet is screened at time of deposit
• Every withdrawal address is screened before processing
• Both sender and recipient are screened for P2P transfers
• Real-time screening (not batch/EOD) for all transactions

Section 3: Ongoing Monitoring

• Re-screening triggered on SDN list updates (daily sync)
• Transaction monitoring for evasion patterns (structuring, chain-hopping)
• Mixer and privacy-coin interaction flagged for enhanced review
• Screening logs retained for 5+ years and searchable by regulator request