What is OFAC compliance for peer-to-peer platforms?

P2P platforms must screen both parties to every transaction against the SDN List, because the platform is the intermediary.

TL;DR

TL;DR: P2P compliance means screening both the buyer and the seller on every transaction, and blocking any match, because the platform that connects them can be liable for facilitating a prohibited deal.

The intermediary problem

A peer-to-peer platform brings two parties together and moves value between them. That makes it the intermediary, and OFAC applies strict liability, so the platform can be liable even without intent when it facilitates a sanctioned transaction. The platform cannot hide behind "the users did the deal."

Screen both parties

• Buyer: check the name and paying wallet.
• Seller: check the name and receiving wallet.
• Ownership: apply the 50 Percent Rule to majority owned entities.

Controls

Screen at match time and again at settlement, since designations can change between the two. Run the check under 100 ms so the marketplace stays fast. Log every screen, and block the trade when either party matches the SDN List.

Escrow is not a shield

Platforms that hold funds in escrow are not insulated from the obligation; if anything, holding the value makes the platform's role more direct. Screen both parties before funds enter escrow and again before release. A match at either point means the deal stops, the funds are not moved, and the platform documents the block. Keep the screen and the block decision in the same place so a match stops the deal immediately, and log the refusal with the trade record for later review.