Sanctions Risk Assessment Template

The scored sanctions risk assessment template for payment and agent teams.

How to use

How to use: complete annually and after any material product change. Score each dimension 1–5.

The assessment

1. Product surface. Do your products move money? [score]
2. Counterparty types. Wallets, named entities, corporate structures? [score]
3. Geographies. Do you touch any of the 16 embargoed jurisdictions? [score]
4. Agent autonomy. Do agents transact without human review? [score]
5. Volume. Transaction volume and values [score]

Total risk: [sum]. Low (5–10): wallet screen + log. Medium (11–18): + name screening + review queue. High (19–25): + full program + counsel review.

Why the template exists

Risk assessment is one of the five pillars OFAC expects. This template turns it into a scored, documented artifact.

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