Stablecoin Sanctions Compliance
The stablecoin-specific sanctions compliance playbook for issuers, platforms, and agents.
Why stablecoins get scrutiny
Stablecoins (USDC, USDT) are the rails for agent payments — fast, cheap, and programmatic. OFAC enforcement has targeted stablecoin flows, and issuer controls (blocklists) exist precisely because sanctions apply.
The two control layers
- Issuer layer: Circle/Tether blocklists and freeze capabilities
- User layer: your screen before every transfer — the blocklist is not your compliance program
The agent angle
An agent paying in USDC is your company transacting. The x402 payment flow settles USDC without a human — which means the screen has to be a call, not a review.
The playbook
- Screen every destination before signing
- Screen across chains (Base, Ethereum, Tron)
- Log every result for the audit trail
- Re-screen on list updates (hourly sync)