OFAC sanctions compliance for fintech

Fintech must screen at the moment of payment because the payment rails themselves do not screen.

TL;DR

TL;DR: Fintech platforms must add their own screening because payment and agent rails such as x402, AP2, ACP, and Coinbase AgentKit move money but do not screen for OFAC, so the screening step belongs at the moment of payment.

Payment rails do not screen

A key gap is that the rails that move money do not check sanctions. x402, AP2, ACP, and Coinbase AgentKit all transfer value, but none of them performs OFAC screening on the counterparty. That means the fintech building on top of them is the party responsible for the check, and OFAC liability is strict.

Screen at the payment moment

The right place for screening is immediately before a payment is authorized, where a single HTTP call under 100 ms returns ALLOW or BLOCK. This keeps latency low enough for real-time payments while closing the compliance gap. The 4-Gate protocol (SCREEN, SCORE, STOP, STAMP) captures this flow and records the decision.

Integrations

• x402: $0.05 per check at payment time.
• MCP: pip install sanctions-mcp.
• Base/USDC: screening for stablecoin payment paths.