OFAC screening for OTC trading desks
OTC desks trade large blocks directly with counterparties, so a missed screen is expensive and immediate.
TL;DR
TL;DR: OTC crypto trading desks must screen every counterparty before each trade. Large transactions with unknown or unscreened counterparties are the highest-risk situation.
Why OTC is high risk
An OTC desk settles bilaterally, often without the clearing layer an exchange provides. That means a sanctioned counterparty results in the desk directly moving value to a blocked party, and the larger the block, the larger the exposure. There is no exchange in the middle to absorb the failure.
What to check before each trade
- The counterparty wallet against 947 OFAC-listed crypto wallets.
- The counterparty name against 19,218 SDN names.
- The jurisdiction, across 16 tracked regions.
- Re-check on every trade, not just at onboarding.
How to operationalize it
Screen before each trade with a single HTTP call under 100 ms. sanctionsai.dev returns clean equals ALLOW and flagged equals BLOCK, so the desk can block a trade before any value moves.