OFAC red flags
Payments to High-Risk Jurisdictions: The OFAC Red Flag List
Geography still matters in crypto. A payment routed through a comprehensively sanctioned jurisdiction is presumptively a violation regardless of the currency. This is the red flag matrix every payment agent should hard-code.
| Red flag | Why it triggers OFAC scrutiny | Risk level |
|---|---|---|
| Comprehensive sanctions jurisdictions | Iran, North Korea, Cuba, Syria, and Crimea/DNR/LNR are subject to comprehensive embargoes. Nearly any transaction involving these jurisdictions is prohibited. | Critical |
| Russia sectoral and SDN exposure | Russia is not under a comprehensive embargo, but EO 14024 and dozens of sectoral programs designate banks, oligarchs, and tech firms. Counterparty screening against the Russia program is mandatory. | High |
| Transshipment through a third country | Routing a payment through a clean jurisdiction to obscure a sanctioned end-party is itself an evasion pattern and a red flag for both OFAC and your banking partner. | High |
The control: every red flag above is caught by pre-transaction OFAC screening.
SanctionsAI checks the wallet, name, or jurisdiction against the live SDN list in under 100ms,
before the payment is signed. There is no pattern so clever that it bypasses an address check.
What to do if you see one of these
- Stop the transaction. Do not let the agent retry around the screen.
- Log the event with timestamp, subject, and SDN list version (the audit trail is your defense).
- If a payment already executed, preserve evidence and assess voluntary self-disclosure — it can reduce a penalty by up to 50%.
- Review the agent's control path: was the screen on the actual execution path, or only on the happy path?
Block every red flag before the payment signs
Pre-transaction OFAC screening in under 100ms. Free tier: 5 checks/day, no signup.
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