OFAC screening for crypto ATMs

Crypto ATMs must verify user identity and screen each transaction against the SDN List at the point of sale.

TL;DR

TL;DR: A crypto ATM must screen the user and the transaction against the SDN List before completing a buy or sell. KYC and OFAC screening are both required.

Why ATMs are a chokepoint

An ATM converts cash and crypto in person, often with limited human oversight. That makes it an attractive on-ramp, so operators face real compliance expectations. OFAC applies strict liability, meaning intent is not required for a violation. A machine that hands crypto to a designated person is the operator's exposure.

What to screen at the kiosk

• Identity: match the user to a name via KYC.
• Name: check the customer name against SDN names.
• Wallet: check the deposit or withdrawal address against listed crypto wallets.

Operational controls

Run the check before the machine dispenses or accepts funds. A screening API that returns in under 100 ms fits the kiosk flow. Log every screen, and block the transaction when a name or wallet matches. Automated screening lets the kiosk act without a compliance officer on site, and the log preserves the evidence of each decision.

KYC and OFAC are not the same thing

KYC verifies identity, while OFAC screening checks that identity against the SDN List. A customer can pass KYC and still be a designated person. The two checks run together at the kiosk: KYC establishes who the person is, and OFAC screening decides whether the transaction may proceed. Both must pass before the machine dispenses or accepts funds.