OFAC compliance for fintech infrastructure

Fintech infrastructure like banking-as-a-service, card issuing, and ACH processing must embed screening throughout.

TL;DR

TL;DR: Fintech infrastructure providers should embed screening into every money-moving service, from card issuing to ACH, since each carries the same strict-liability exposure.

The infrastructure footprint

Fintech infrastructure, banking-as-a-service platforms, card issuers, and ACH processors, moves money on behalf of many downstream products, which concentrates sanctions exposure. Each transaction touches a counterparty that could be a Specially Designated National, and OFAC applies strict liability to every one, with civil penalties starting at $356,000 per violation.

Embedding screening

Embedding screening means putting the check inside each money-moving service. A card authorization, an ACH transfer, or a bank account opening should each run a screening call that returns ALLOW or BLOCK in under 100 ms. The check covers 19,218 SDN names and 947 OFAC-listed crypto wallets and applies the 50 Percent Rule, so ownership by a blocked person is caught too.

The shared control

Because infrastructure serves many clients, a single shared screening service keeps the control consistent and the audit trail unified. Log every result, and the provider can demonstrate to regulators, and to its own customers, that screening runs at every hop.

Integrations for infrastructure teams

Infrastructure teams can wire screening into the interfaces they already expose. MCP support covers agent-driven flows, and integrations with x402, Base/USDC, and Coinbase AgentKit cover on-chain and per-check paths. Because the control is one HTTP call returning ALLOW or BLOCK, embedding it across services stays thin.