OFAC screening for subscription payments
Subscriptions recur, and a customer's sanctions status can change between billing cycles.
TL;DR
TL;DR: Recurring subscription payments must be screened not just at signup but periodically, because SDN status can change between billing cycles and a previously clean customer can become blocked.
Why re-screening matters
A customer can be added to the SDN List at any time. A subscription that keeps charging a newly blocked customer is an ongoing transfer to a blocked party. A one-time signup screen goes stale the moment a list updates.
What to do
- Screen at signup.
- Re-screen before each renewal or billing cycle.
- Use hourly-synced data.
- On a flagged result, BLOCK and pause billing.
How to fit it in
One HTTP call under 100 ms before each charge keeps billing fast while staying current. sanctionsai.dev returns ALLOW for clean and BLOCK for flagged, so a blocked customer is paused rather than charged.