OFAC screening for token vesting

Vesting pays tokens on a schedule, which means multiple distribution points that each need a screen.

TL;DR

TL;DR: Token vesting schedules that distribute tokens to wallet addresses over time must screen recipients at each distribution point, because a recipient can become sanctioned between disbursements.

Why each point matters

A recipient who is clean at grant time can be added to the SDN List later. Screening only at grant misses that change, and each subsequent distribution would be a transfer to a blocked party. Status is a moving target, not a one-time check.

What to screen

• The recipient wallet before each unlock or cliff.
• Recipient identity against 19,218 SDN names.
• Fresh data, since sanctionsai.dev syncs hourly.

Practical controls

Screen before each distribution and hold any tranche where the result is flagged equals BLOCK. The 4-Gate Agent Payment Protocol applies here too: SCREEN, SCORE, STOP, STAMP at every vesting event.