OFAC compliance for multisig wallets

How multisig wallet operators can screen signers and destinations to avoid sanctions exposure.

TL;DR

TL;DR: Multisig wallets add signers but not screening. Operators should check both the counterparty and the destination before the final signature settles a payment.

Where multisig adds risk

A multisig wallet spreads signing across several keys, but the transaction still settles to one destination. If that destination is on the SDN List, the payment violates OFAC regardless of how many signers approved it. Strict liability applies, so intent is not a defense and penalties start at $356,000 per violation.

Screening before the final signature

The right control is a check before the last signer commits. sanctionsai.dev's sanctions_check returns ALLOW or BLOCK in under 100 ms, so a wallet UI can screen the destination and show signers the result before they approve. Screening 947 OFAC-listed crypto wallets and 19,218 SDN names means a flagged destination is caught before funds move.

What to show signers

Surface the screening result in the signing flow. A clean ALLOW lets signers proceed with confidence, while a BLOCK or a high risk_score pauses the transaction for review. Keep a STAMP record of each check so the wallet can show the screening happened if the destination is later sanctioned.

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