Marketplace Sanctions Screening
The marketplace payment-hub compliance shape.
Overview
A marketplace sits between buyers and sellers - every payout is a payment path. BitPay's $507K settlement was exactly this shape: merchant payments to users in sanctioned jurisdictions.
The four surfaces
- Seller onboarding - name + ownership (50% rule)
- Buyer jurisdiction - the 16-jurisdiction screen
- Payout wallets - every settlement address
- Refunds - returns are payments too
The control
Screen at onboarding and on every payout, screen refunds, fail closed, log with list versions. The screening log template structures the trail.
Why it matters
Marketplace volume compounds exposure - hundreds of payouts a day, each a potential violation. The screen is the only control that scales.