OFAC screening for payment facilitators

A payment facilitator underwrites many sub-merchants, so it screens both the merchant and each transaction.

TL;DR

TL;DR: Payment facilitators processing transactions for sub-merchants must screen every merchant and every transaction, because the facilitator is the party of record moving the funds.

Why the facilitator is responsible

The facilitator is the master merchant of record and routes settlement to its sub-merchants. If a sub-merchant is sanctioned, the facilitator is paying a blocked party. The sub-merchant relationship does not shift that liability away from the facilitator.

What to screen

• Merchant identity at onboarding.
• Merchant counterparties before every transaction.
• Jurisdiction across 16 tracked regions.
• Re-screen merchants as lists update hourly.

Practical controls

Screen at onboarding and again on each transaction. sanctionsai.dev returns ALLOW for clean and BLOCK for flagged in under 100 ms, and follows the SCREEN, SCORE, STOP, STAMP protocol so every clean decision is recorded.