OFAC sanctions compliance for exchanges

Exchanges need a running compliance program that screens, scores, stops, and records every transaction.

TL;DR

TL;DR: Exchange sanctions compliance is a continuous program, not a one-time setup: screen every counterparty, score the risk, stop flagged transactions, and stamp each decision into an audit record.

A program, not a checkbox

Exchanges process a high volume of counterparties across fiat and crypto, so compliance must run continuously rather than once at onboarding. OFAC liability is strict and penalties start at $356,000 per violation, and under the 50 Percent Rule an entity 50 percent or more owned by a blocked person is itself blocked. A static onboarding check will miss a counterparty designated after signup.

The four gates in operation

The 4-Gate Agent Payment Protocol maps directly onto exchange operations: SCREEN the counterparty against the SDN List and listed wallets, SCORE the risk, STOP the transaction if flagged, and STAMP the decision into a log. Each step is a single call or a recorded outcome, so the whole flow runs in under 100 ms per screening.

Operationalizing it

sanctions_check handles the decision, risk_score adds a risk view, kya_verify documents the counterparty, and dispute_open gives users a review path. Pricing scales from a free tier to Pro at $99 per month for 100,000 checks, with a MIT-licensed self-hosting option for exchanges that want to run it inside their own stack.