Onboarding
A customer who matches a list
"At onboarding you detect a possible match with a sanctions list; screening determines whether it is a false positive or a real block."
Crypto Sanctions Screening (OFAC, EU, UN)
A crypto firm must screen customers, wallets and counterparties against the sanctions lists of the EU, the UN and OFAC. We design your sanctions controls: list selection, screening at onboarding and on every transaction, match handling and reporting, integrated into your anti-money laundering program and your MiCA compliance.
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How we help
Your sanctions controls, end to end
Six areas to put robust sanctions screening in place at a crypto firm: lists, screening, wallets, matches, reporting and governance.
Lists
List selection and maintenance
We define which lists apply to your business (EU, UN and OFAC, depending on the nexus) and how to keep them up to date so your screening does not become obsolete.
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EUUNOFACUpdates
Screening
Screening at onboarding and on transactions
We design when screening takes place: at customer onboarding, on each relevant transaction and on an ongoing basis against updated lists, integrated with your transaction monitoring (KYT).
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OnboardingTransactionsKYT
Wallets
Wallet and address screening
We screen addresses and wallets against sanctions lists and on-chain intelligence to detect exposure to sanctioned entities or addresses.
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On-chainAddresses
Matches
Match handling
We set out how to analyze alerts, clear false positives and escalate true matches, with an audit trail for every decision.
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False positivesEscalation
Reporting
Freezing and reporting
We define how funds are frozen and how this is reported to the competent authorities when there is a match with a sanctioned person or entity.
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FreezingSEPBLAC
Governance
Sanctions policy and governance
We document the sanctions policy, roles and controls within your compliance program and your CASP application under MiCA.
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PolicyMiCA
Situations
When screening makes the difference
Sanctions screening is not a formality: it is what stops you from executing a transaction with a blocked person, entity or address.
Wallet
An address with sanctions exposure
"A wallet that interacts with sanctioned addresses requires on-chain screening before you accept or execute the transaction."
Counterparty
A transfer to a listed entity
"Before you move funds to another platform or country, screening checks that the counterparty is not on a sanctions list."
US nexus
Dollar transactions or business with the US
"If there is a US nexus (USD or US infrastructure), OFAC comes into play in addition to the EU and UN lists."
What is at stake
Failing to screen for sanctions has serious consequences
Dealing with a sanctioned person or entity can lead to administrative penalties, liability and even the blocking of your operations. Sanctions controls are part of your due diligence obligations.
EU sanctions
Mandatory
EU restrictive measures are directly applicable and binding on entities operating in Spain.
Law 10/2010
Due diligence
Sanctions screening is part of your anti-money laundering and counter-terrorist financing (AML/CFT) obligations.
OFAC: where there is a US nexus (USD, infrastructure), its lists also apply and a breach can have extraterritorial consequences.
Outdated lists: screening against old lists is the same as not screening at all; the lists change frequently.
MiCA
Required
A CASP must demonstrate robust sanctions controls as part of its governance and compliance.
No audit trail: failing to document decisions on matches makes it impossible to prove due diligence to the supervisor.
Need to implement sanctions screening?
We help you choose the lists, define your screening, handle matches and document the policy within your compliance program.
Frequently asked questions
Sanctions screening: common questions
What is sanctions screening?
It is the process of screening customers, counterparties and wallets against sanctions lists so that you do not deal with persons or entities subject to restrictive measures. It is part of the due diligence of any obliged entity.
What is OFAC and why is it mentioned so often in crypto?
OFAC (Office of Foreign Assets Control) is the US office that manages the US sanctions lists. It comes up a lot in crypto because of the weight of the dollar and of US infrastructure, but it is not the only relevant list.
Is a Spanish entity subject to OFAC?
A Spanish entity is subject above all to EU and UN sanctions, which are directly applicable. OFAC lists apply when there is a US nexus (transacting in dollars, using US banks or infrastructure, etc.). That is why good controls screen against all of them.
Which lists should I screen against?
At a minimum, the EU and UN sanctions lists. Depending on your business, also the OFAC lists and other national lists. The selection depends on your markets, currencies and counterparties, and must be documented in your policy.
When does screening have to take place?
At customer onboarding, before relevant transactions and on an ongoing basis against updated lists, because someone may be added to a list after they have been onboarded. In crypto, this is complemented by screening wallets and addresses.
What do I do if a match comes up?
You need to analyze the alert and either clear it as a false positive or confirm the match. If it is a true match, you must block the transaction or the funds and report it to the competent authorities, keeping an audit trail of every decision.
How does screening relate to KYT?
They are complementary. Sanctions screening checks against lists of persons and entities; KYT (transaction monitoring) analyzes the behavior and on-chain risk of transactions. Together they cover sanctions risk and money laundering risk.
Does MiCA require sanctions controls?
A CASP must have solid governance and a solid compliance program, and sanctions controls are an essential part of that framework, alongside anti-money laundering. Well-designed screening strengthens your authorization application and your day-to-day operations.
Contact
Book a call
Tell us about your business and your customer base, and we will tell you which lists, controls and match review process your sanctions screening needs.
Official sources
Key legislation, linked to the official text:
- Law 10/2010 of April 28 on the prevention of money laundering and terrorist financingBOE · consolidated text
Legislation and links reviewed in .