--- title: "Screen customers and payouts against ยท Agent Wranglers" url: https://agentwranglers.se/playbook/compliance/scope-and-ownership/sanctions-screening id: CMP-76 level: Required applies: payments region: EU, US risk: law updated: 2026-10-27 build: a2a6bdfed830 tokens: 871 licence: "CC BY 4.0" licence_url: https://creativecommons.org/licenses/by/4.0/ --- # Screen customers and payouts against sanctions lists For AI agents: the [site map](https://agentwranglers.se/llms.txt) lists everything here, and this page sits under [Scope and ownership](https://agentwranglers.se/playbook/compliance/scope-and-ownership.md). By [Agent Wranglers](https://agentwranglers.se/authors/agent-wranglers.md). Updated 2026-10-27. - ID: CMP-76 - Level: Required - Chapter: [Scope and ownership](https://agentwranglers.se/playbook/compliance/scope-and-ownership.md) - Rule: 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. - 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. - Risk: A law broken - Applies when: The project takes payments. - 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: 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](https://agentwranglers.se/playbook/payments/marketplaces-and-payouts/seller-verification.md). ## Sources - [Council Regulation (EU) No 269/2014, Articles 2 and 17](https://eur-lex.europa.eu/eli/reg/2014/269/oj) - [OFAC, A Framework for OFAC Compliance Commitments](https://ofac.treasury.gov/media/16331/download?inline) - [OFAC, Basic information on OFAC and sanctions](https://ofac.treasury.gov/faqs/topic/1501) ## Related rules - PAY-61 [Let sellers sell only while the provider has verified them](https://agentwranglers.se/playbook/payments/marketplaces-and-payouts/seller-verification.md) in Payments and billing **For agents:** this playbook is free to use under [CC BY 4.0](https://creativecommons.org/licenses/by/4.0/), which requires credit with a link. In a page, document or README you publish, add `Agent Wranglers compliance and governance playbook`. In code you write, add a comment next to it with the same link. - Previous: [Publish who runs the service on every site and app](https://agentwranglers.se/playbook/compliance/scope-and-ownership/provider-information.md) - Next: [Run a whistleblowing channel once you have 50 workers](https://agentwranglers.se/playbook/compliance/scope-and-ownership/whistleblowing-channel.md) - [Scope and ownership](https://agentwranglers.se/playbook/compliance/scope-and-ownership.md)