UNICORN PRIVATE Sanctions risks for fintech and payment companies: what to check
In short
Fintech and payment companies move money for many customers, often in real time.
The main risks are listed customers, payments to or from listed parties and owners hidden behind other companies.
Screen customers at onboarding and every day after, and check the parties to each payment.
Typical sanctions risks in this industry
- Onboarding customers who are listed or owned by listed persons.
- Processing payments to or from listed persons, banks or countries.
- Customers who become listed after onboarding, if the check is done only once.
- Use of intermediaries, shell companies or crypto assets to hide the real parties.
- Payments in US dollars that bring the transaction under US rules.
Recommended checks
- Screen customers and their beneficial owners at onboarding and every day after.
- Check the parties and the banks of each payment against the sanctions lists.
- Apply the ownership rules: entities owned or controlled by listed persons can be covered too.
- Review possible matches quickly and document every decision.
- Keep records of the checks and of the decisions taken.
Official sources
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Frequently asked questions
Is a check at onboarding enough?
No. The lists change often, so customers should be checked again every time the lists are updated.
Do sanctions apply to crypto payments?
Yes. Sanctions prohibit making funds and economic resources available to listed parties, and crypto assets are included.
What should we do with a possible match?
Check the details, such as date of birth, country and identifiers. If the match is confirmed, stop the transaction and follow the reporting rules of your country.
The program can make mistakes. The final responsibility for compliance stays with your company. Unicorn Intelligence is an information tool. Decisions and legal obligations, including sanctions compliance, due diligence and tender participation, remain with the customer.
Unicorn Intelligence checks your clients and suppliers against the sanctions lists every day.