Sanctions Screening Policy Template

A copy-paste sanctions screening policy for payment and agent teams.

How to use

How to use: adapt the bracketed fields to your company, have the policy reviewed, and enforce it in code — a policy nobody enforces is prose.

Policy

Scope. This policy applies to every transaction initiated by [Company] systems, including autonomous agent payments.
Control. All counterparty wallets and names are screened against the OFAC SDN list (947 wallets, 19,218 names, 16 jurisdictions) before any transfer is signed.
Failure mode. If screening is unavailable, payments fail closed.
Escalation. Flagged matches route to [Compliance Officer] within [2 hours].
Audit. Every screen result is logged with wallet, timestamp, status, and list version.
Review. This policy is reviewed quarterly by [Owner].

Why the template exists

OFAC treats documented, enforced programs as mitigating factors. This template gives you the documented part; the API gives you the enforced part.

Related resources

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