OFAC screening for enterprise blockchain

Enterprise blockchain networks must screen the participants and transactions on their ledger against the SDN List.

TL;DR

TL;DR: Enterprise networks such as permissioned ledgers still process value, so the operator must screen participating entities and their transactions against the SDN List before settlement.

Why enterprise chains are not exempt

A permissioned ledger does not escape OFAC. Value still moves between known parties, and the network operator is the natural control point. Strict liability applies, so intent is not required. Being "enterprise" or "permissioned" does not change the obligation, it only changes who is accountable.

What to screen

• Participants: check each onboarded entity's name against SDN names.
• Wallets: check each account address against listed crypto wallets.
• Ownership: apply the 50 Percent Rule to majority owned entities.

Implementation

Screen at onboarding and again before each settlement, because designations can change after an entity joins the network. Because the ledger may be automated by smart contracts or agents, an API that returns in under 100 ms keeps settlement fast. Log every screen so the network can demonstrate coverage during an audit.

Who is accountable

On a permissioned ledger the operator, not a diffuse set of nodes, is the accountable party. That makes screening more tractable: the operator knows the participants and can check each one. But it also concentrates the obligation. A missed designation on a known participant is hard to defend, so screen every entity and every settlement and keep the log. Keep a register of every screened participant and every settlement decision, so the network can point to a specific record for any transaction under review.