Prompt

I'm building a crypto onboarding flow and need sanctions screening plus KYC

Legal / Compliance & Regulatory1 observationLast seen Oct 5, 2026

Latest observation

Oct 5, 2026OpenAI APIWeb search: off

For a crypto onboarding flow, you usually want to treat this as KYC + sanctions/PEP screening + ongoing monitoring, with the exact depth depending on your business model and jurisdictions.

What you likely need

1) Identity verification (KYC)

Core checks typically include:

  • Legal name
  • Date of birth
  • Residential address
  • Government-issued ID verification
  • Selfie/liveness check
  • Phone/email verification

2) Sanctions screening

Screen customers against:

  • OFAC
  • UN
  • EU
  • UK HMT
  • Other relevant local sanctions lists

Also usually screen:

  • Watchlists
  • PEPs
  • Adverse media
  • Potentially known crypto-risk indicators, depending on risk appetite

3) Ongoing monitoring

Not just at onboarding:

  • Re-screen when lists update
  • Monitor for changes in risk profile
  • Periodic refresh of KYC data
  • Transaction monitoring, if required by your program

Common implementation pattern

Basic flow

  1. User signs up
  2. Collect identity data
  3. Collect document + selfie
  4. Run sanctions/PEP screening
  5. If pass, allow onboarding
  6. If hit/manual review, queue for compliance review
  7. Set up ongoing re-screening

Risk-based flow

  • Low risk: automated approve
  • Medium risk: extra checks or manual review
  • High risk: enhanced due diligence or deny

Vendor options

Many teams use a provider that bundles these functions. Common categories:

  • Identity/KYC: Persona, Onfido, Veriff, Sumsub, Sardine
  • Sanctions/AML screening: ComplyAdvantage, Refinitiv, Dow Jones, LexisNexis Risk, Sanctions.io
  • Crypto compliance / chain monitoring: Chainalysis, TRM Labs, Elliptic

Some vendors cover multiple parts so you can reduce integration complexity.


Important design considerations

False positives

Sanctions screening often creates name matches that are not actual matches. You’ll need:

  • Matching thresholds
  • DOB/country disambiguation
  • Manual review workflow
  • Audit trail for decisions

Jurisdiction

Requirements vary a lot by:

  • Where your company is licensed
  • Where your users are located
  • Whether you custody funds
  • Whether you offer fiat on/off ramp
  • Whether you support retail or institutional users

Data privacy

You’ll need to think about:

  • Data minimization
  • Retention periods
  • Encryption
  • Access controls
  • Consent/notice
  • Cross-border data transfer rules

Practical recommendation

If you’re just starting:

  1. Pick one onboarding vendor for ID verification
  2. Add a dedicated sanctions/PEP screening API
  3. Build a manual review queue
  4. Add ongoing re-screening
  5. If you touch crypto transactions, add wallet/transaction screening later

Example rule set

A simple policy might be:

  • Block if confirmed sanctions match
  • Manual review if potential sanctions hit
  • Block if user is in prohibited jurisdiction
  • Enhanced due diligence if PEP or adverse media hit
  • Re-screen every 24 hours or on list updates

If you want, I can help you with any of these next:

  1. a vendor shortlist
  2. a technical architecture
  3. a sample compliance workflow
  4. a database schema / API design
  5. a jurisdiction-specific checklist

Observation history

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