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One free scan finds every outdated or missing driver and matches the right update for your exact hardware.Free scan · exact hardware matchUse a documented, risk-based process: determine which sanctions rules apply to your business, screen customers and transaction data before acceptance or processing, investigate possible matches, record the decision, and rescreen when lists or risk information change. A wallet alert is a reason to review—not, by itself, proof of who controls the wallet or a final legal determination.
How do I screen crypto transactions for sanctions before accepting them?
Build the screening process around your jurisdiction, services, customers, supported assets, custody arrangements, and transaction flows. Then apply these steps at the points in your flow where you can still pause or prevent acceptance or processing.
- Map your legal and operational scope. Identify the jurisdictions connected to the business and its transactions, the sanctions authorities and lists relevant to those connections, the customer types you serve, and the assets and services you support. Record why those rules and lists apply. The precise scope cannot be determined without facts about your business.
- Screen customers and counterparties. At onboarding, compare available customer and counterparty information with the relevant sanctions lists. Use matching that can catch common variations in spelling, spacing, punctuation, and capitalization, while routing possible matches for review rather than treating every name similarity as confirmed.
- Screen transaction information before the relevant processing point. Depending on the transaction and information available, check originator and beneficiary details, physical and digital wallet addresses, IP addresses, geographic indicators, and other relevant transaction data. The appropriate timing and controls depend on your transaction flow and applicable rules; official guidance does not establish one universal technical threshold.
- Investigate address exposure and transaction context. Compare wallet addresses and, where appropriate, transaction paths with applicable official list data and risk information. Blockchain analytics can help trace funds and flag exposure, but an indirect connection is an investigative lead, not a conclusion about identity or a sanctions violation.
- Escalate, decide, and document. Have trained compliance staff review potential name, address, location, and transaction matches under written procedures. Record the data screened, list and tool versions, the match rationale, relevant review, escalation, and disposition in line with applicable recordkeeping and retention requirements.
- Rescreen and improve controls. Use risk-based triggers such as changes to sanctions lists, customer information, or transaction risk to decide when to screen again. Test whether list and geographic screening flag cases for review, train relevant staff, and address weaknesses. When an address is newly listed, consider whether a historical lookback is appropriate.
Which sanctions rules and lists should the business screen against?
There is no single sanctions list that applies to every crypto business worldwide. Start with the business’s legal connections and applicable obligations; do not assume that U.S. and UK requirements are interchangeable or that every business is subject to OFAC jurisdiction.
| Context | What the cited guidance establishes | How to apply it |
|---|---|---|
| United States | OFAC FAQ 560 says U.S. persons and persons otherwise subject to OFAC jurisdiction have sanctions obligations for digital currency comparable to those for fiat currency. It also describes the 50 Percent Rule: entities owned in the aggregate, directly or indirectly, 50 percent or more by blocked persons are treated as blocked. | Determine whether OFAC jurisdiction applies to your facts, identify relevant restrictions and list data, and assess ownership as well as direct name or address matches. |
| United Kingdom | UK firms should follow UK sanctions requirements and reporting channels. The FCA-hosted joint statement, first published March 11, 2022 and updated February 6, 2026, discusses risk assessments, list screening, effective rescreening, contextual red flags, and UK reporting considerations. | Use the UK rules and relevant updated lists that apply to the firm; do not substitute OFAC procedures for UK obligations. |
| New York virtual currency businesses covered by the guidance | NYDFS’s April 28, 2022 blockchain analytics letter is directed to businesses licensed under 23 NYCRR Part 200 or chartered as limited purpose trust companies under New York Banking Law. | Treat its analytics guidance as applicable to the covered entities, not as a universal rule for every business or jurisdiction. |
OFAC recommends a routine and, where appropriate, ongoing risk assessment tailored to a company’s exposure; it rejects a one-size-fits-all program. The exact list set for a particular business depends on facts that are not specified here. Sanctions rules and lists can change, so verify the current requirements with the relevant official authority and qualified counsel.
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What information should a crypto sanctions screen include?
Do not limit screening to a wallet address. OFAC’s virtual currency guidance recommends screening customer information at onboarding and transaction information, including physical addresses, digital wallet addresses, IP addresses, and other relevant information.
- Customer and counterparty identifiers: names and other available identifying information, including variations that may arise from spelling, spacing, punctuation, or capitalization.
- Transaction parties and endpoints: available originator and beneficiary details, wallet addresses, and information about relevant exchanges or custodians.
- Geographic and supporting data: physical addresses, IP or geolocation information, and other transaction details relevant to the risk and applicable rules.
The information available varies by product and transaction design. Document which fields you collect and screen, and where a missing field affects the strength of a review; do not imply that on-chain data alone answers every identity question.
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How should staff investigate a wallet or customer alert?
Separate an alert from a confirmed match
Screening systems are designed to surface candidates for review. A name similarity, geographic signal, or indirect wallet exposure should be checked against identity details, ownership information, the transaction path, customer profile, relevant sanctions program, and other available facts. OFAC recommends matching logic that catches common name variations; UK guidance likewise emphasizes assessing indicators in context.
Use blockchain analytics as supporting evidence
Analytics may help trace flows and identify institutional or known high-risk addresses. NYDFS cautions that such tools may not identify the underlying owner or ultimate beneficial owner without off-chain verification, such as customer-provided information. A risk score or connection shown by a tool should therefore be treated as an input to review, not proof of who controls an address.
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Assess red flags in context
UK guidance identifies examples including a customer or transaction connected with a sanctioned or higher-risk jurisdiction; funds involving a sanctioned or high-risk wallet address; use of a high-risk exchange or custodian; and attempts to obscure location or cryptoasset source, such as VPNs, proxies, mixers, or tumblers. These indicators warrant contextual review; they do not by themselves establish a breach.
Choose tools for the control you need
Official guidance does not endorse a vendor or show that one product is suitable for every business. When evaluating screening or analytics software, verify capabilities against your flows and control needs:
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- Which sanctions-list sources it uses and how often data is updated.
- Which chains and asset types it supports, and whether it can trace addresses and transaction paths relevant to your activity.
- Whether it can incorporate customer data and off-chain verification.
- How configurable and explainable its risk rules and alerts are.
- Whether it supports case management, audit records, testing and validation, data security, and service continuity.
A tool can support a compliance program, but purchasing one does not itself establish that the program meets applicable obligations.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What should happen after a possible match?
Use written procedures to route potential matches to appropriately trained reviewers, set out what evidence they examine, and specify who can authorize a disposition. The appropriate action—such as holding for review, blocking, rejecting, or proceeding—depends on the facts and jurisdiction. A potential alert alone does not settle that choice.
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If a U.S. blocking obligation is confirmed
For a U.S. person subject to a blocking requirement, OFAC FAQ 646 says blocked virtual currency must be held so all parties are denied access. OFAC says the blocking report is due within 10 business days, followed by annual reporting while the assets remain blocked. Confirm the current requirements and obtain qualified advice for the specific facts before acting.
Keep a review record
For each investigated alert, retain an appropriate record of what was screened, the relevant list and tool versions, the facts considered, the match analysis, any escalation, and the decision. Apply the retention rules relevant to the business and jurisdiction; the sources cited here do not establish one universal retention period.
How should the screening program be maintained?
Screening is not only an onboarding or one-time transaction check. OFAC recommends ongoing, risk-based rescreening when customer data, sanctions lists, or requirements change. UK guidance also discusses effective rescreening against updated lists.
- Set risk-based triggers for rescreening relevant customers, counterparties, addresses, and, where warranted, historical activity.
- Test list screening and geographic screening, including whether relevant keywords and variations produce cases for review.
- Train staff who operate, investigate, approve, or maintain screening controls.
- Review control failures and remediate weaknesses; consider a lookback when a relevant address is newly listed.
The frequency, thresholds, and technical design should reflect the business’s risks and applicable requirements. The cited sources do not prescribe a single alert threshold, hold period, or screening schedule for all crypto transactions.
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