On September 30, 2022, the OFAC published the Sanctions Compliance Guidance for Instant Payment Systems, which emphasizes the importance of taking a risk-based approach to managing sanctions risks in the context of new payment technologies such as instant payment systems and to highlight considerations relevant to managing those risks. The guidance also encourages developers of instant payment systems to incorporate sanctions compliance considerations and features as they develop these systems.
Through the guidance, the OFAC recommends that U.S. persons, including U.S. banks, employ a risk-based approach to sanctions compliance by developing, implementing, and routinely updating a sanctions compliance program. The OFAC also suggests that in assessing and mitigating sanction risks in instant payment systems, institutions should consider other risk factors such as domestic vs. cross-border payment systems, nature and value of payment, and availability of emerging sanctions compliance technologies and solutions.
The OFAC’s compliance guide can be found here.