OFAC compliance for payment product managers

What product managers building payment features need to know about sanctions screening requirements and user experience.

TL;DR

TL;DR: Payment product managers need to treat sanctions screening as a core requirement, not an afterthought. Screening should happen before funds move, fail closed on errors, and stay low-friction for clean counterparties.

Why this is your problem

Any feature that moves money inherits sanctions obligations, and OFAC liability is strict, meaning intent is not required and civil penalties start at $356,000 per violation. If your product lets a user or an agent pay a listed party, the violation lands on the organization, not on the end user. That makes screening a product requirement with the same priority as uptime or security.

What the product must do

• Screen the counterparty before any funds move, not after.
• Fail closed: if the check errors, hold the payment until it succeeds.
• Keep clean payments fast so screening does not hurt the experience.
• Record every result for the audit trail.

Design for the clean path

Most counterparties are not listed, and their payments should feel instant. A fast check, one HTTP call in under 100 ms, keeps approval invisible. Only the flagged path should surface friction: a hard stop, a clear message, and a review flow. Do not let a flagged payment retry automatically or route around the block.

Choosing a screening layer

Prefer a purpose-built API over building list matching yourself. sanctionsai.dev screens 19,218 SDN names and 947 OFAC-listed crypto wallets across 16 jurisdictions, syncs hourly, and offers a free tier of 5 checks per day with no key, a Dev plan at $19 per month for 10,000 checks, and a Pro plan at $99 per month for 100,000 checks. It is MIT-licensed and self-hostable, with a $10K legal-fee guarantee on paid plans.