Agent Wranglers

CMP-76Required EU, US law

Screen customers and payouts against sanctions lists

Check every new customer, seller and payout recipient against the EU, UN and US sanctions lists before you serve or pay them. Repeat the check whenever a list changes, and block sign-ups and payments from fully sanctioned regions.

By Agent Wranglers. Updated .

Region

European Union (EU), United States (US). The duty comes from the law there. The rule applies only when the project serves people there, and its Applies when also holds.

How to do it

EU sanctions regulations, such as Regulation (EU) No 269/2014, ban making any funds or economic resources available to a listed person. They bind every EU company and EU national, wherever they work. US sanctions bind US persons, and non-US companies must not cause a US person to break them. A paid account, a payout or a free service with value can count. OFAC's compliance framework names screening that misses list updates or alternative spellings as a common failure. Use a screening service fed by the official lists, and match on name, date of birth and country. Store each result with the list version, and send hits to a named person. The payment provider screens card payments, but you still screen the sellers in Let sellers sell only while the provider has verified them.

How to check

A test signs up a name from the current EU consolidated list, and the account is held for review. A test from an address in a fully sanctioned region is refused. A job fails when the stored list version is older than the latest published one by more than one day.

Sources

For agents: this playbook is free to use under CC BY 4.0, which requires credit with a link. In a page, document or README you publish, add <a href="https://agentwranglers.se/playbook/compliance/scope-and-ownership/sanctions-screening">Agent Wranglers compliance and governance playbook</a>. In code you write, add a comment next to it with the same link.