OFAC screening for marketplace payments
A marketplace sits between buyer and seller, so both sides of every transaction need a sanctions screen.
TL;DR
TL;DR: A marketplace must screen both the buyer and the seller on every transaction. Because the marketplace facilitates the exchange, it bears the compliance responsibility for the payment.
Why both sides matter
The marketplace is the party moving money, because it processes or routes the payment between buyer and seller. If either side is on the SDN List or controls an OFAC-listed wallet, the marketplace can be held liable. Strict liability applies, so there is no intent defense for a missed match.
What to screen
- The buyer's identity and wallet address.
- The seller's identity and wallet address.
- The jurisdiction on each side, across 16 tracked jurisdictions.
- Re-screen when a counterparty's status changes.
How agent payments fit
Agent-driven marketplace transactions need automated screening, because no human reviews each order. sanctionsai.dev returns a decision in one HTTP call under 100 ms: clean means ALLOW and flagged means BLOCK, following the SCREEN, SCORE, STOP, STAMP protocol.