OFAC screening for cross-border payments

Cross-border payments multiply sanctions risk because they involve multiple jurisdictions, each with its own sanctions regime. A payment from the US to a European company that routes through a Middle Eastern correspondent bank may touch three sets of sanctions lists.

Why cross-border is higher risk

Every intermediary in the payment chain adds a compliance checkpoint. The US originator is liable for what the correspondent banks do downstream. Screening the ultimate beneficiary is necessary but not sufficient — the payment path matters.