SANCTIONS APPROACH

SANCTIONS APPROACH

Clear boundaries. Actively managed.

Clear boundaries. Actively managed.

Clear boundaries. Actively managed.

Screening runs at three levels — the jurisdiction, the person, and the blockchain address — so a sanctioned country or counterparty can’t reach BTSE’s platform through a gap between them.

Screening runs at three levels — the jurisdiction, the person, and the blockchain address — so a sanctioned country or counterparty can’t reach BTSE’s platform through a gap between them.

World map highlighting jurisdictions where BTSE restricts or prohibits access for licensing, regulatory, or sanctions reasons

Restricted Jurisdictions

At a base level, BTSE applies geo-blocking controls for sanctioned countries: where a jurisdiction is FATF-blacklisted or subject to comprehensive sanctions, BTSE does not make its services available there at all, before any individual-level screening even comes into play.

Cuba

North Korea

Syria

Russia

Iran

World map highlighting jurisdictions where BTSE restricts or prohibits access for licensing, regulatory, or sanctions reasons

Restricted Jurisdictions

At a base level, BTSE applies geo-blocking controls for sanctioned countries: where a jurisdiction is FATF-blacklisted or subject to comprehensive sanctions, BTSE does not make its services available there at all, before any individual-level screening even comes into play.

Cuba

North Korea

Syria

Russia

Iran

World map highlighting jurisdictions where BTSE restricts or prohibits access for licensing, regulatory, or sanctions reasons

Restricted Jurisdictions

At a base level, BTSE applies geo-blocking controls for sanctioned countries: where a jurisdiction is FATF-blacklisted or subject to comprehensive sanctions, BTSE does not make its services available there at all, before any individual-level screening even comes into play.

Cuba

North Korea

Syria

Russia

Iran

Restricted Jurisdictions

At a base level, BTSE applies geo-blocking controls for sanctioned countries: where a jurisdiction is FATF-blacklisted or subject to comprehensive sanctions, BTSE does not make its services available there at all, before any individual-level screening even comes into play.

Cuba

North Korea

Syria

Russia

Iran

Why This Matters

Why This Matters

Why This Matters

Sanctions in crypto apply to both individuals and wallet addresses.
BTSE screens at the identity and address levels to prevent funds from reaching designated wallets.

Sanctions in crypto apply to both individuals and wallet addresses.
BTSE screens at the identity and address levels to prevent funds from reaching designated wallets.

3D illustration of a blocked jurisdiction on a map, marked as prohibited due to FATF blacklisting or comprehensive sanctions

No service.  No exceptions.

No service.  No exceptions.

FATF-blacklisted and/or subject to comprehensive, jurisdiction-wide sanctions.

FATF-blacklisted and/or subject to comprehensive, jurisdiction-wide sanctions.

Reviewed on an ongoing basis.

Reviewed on an ongoing basis.

Access to some or all products may be limited based on external risk data, applicable licensing requirements, and regulatory considerations.

Access to some or all products may be limited based on external risk data, applicable licensing requirements, and regulatory considerations.

3D illustration of a continuous review cycle assessing jurisdictions against risk data, licensing, and regulatory requirements

Major Screening Lists Monitored

Major Screening Lists Monitored

Major Screening Lists Monitored

Customer screening is automated and continuously run on an ongoing basis so a list update is reflected in BTSE’s screening the same way. We use major international and relevant local lists:

Customer screening is automated and continuously run on an ongoing basis so a list update is reflected in BTSE’s screening the same way. We use major international and relevant local lists:

3D icon of a US government building representing OFAC sanctions screening

OFAC (US Treasury)

Specially Designated Nationals & Sectoral Sanctions

3D icon of a UN sanctions list document

UN Security Council

UNSC Consolidated sanctions list

3D icon of a US government building representing OFAC sanctions screening

EU Financial Sanctions

EU Consolidated Financial Sanctions File

3D icon of a US government building representing OFAC sanctions screening

EU Financial Sanctions

EU Consolidated Financial Sanctions File

3D icon of a US government building representing OFAC sanctions screening

UK Sanctions Lists

UK lists issued by OFSI/HMT and other government bodies

3D icon of a US government building representing OFAC sanctions screening

UK Sanctions Lists

UK lists issued by OFSI/HMT and other government bodies

Screening Flow

Screening Flow

Screening Flow

01

01

Geo-blocking

Geo-blocking

Access is blocked at the jurisdiction level for comprehensively sanctioned countries.

Access is blocked at the jurisdiction level for comprehensively sanctioned countries.

02

02

Onboarding screening

Onboarding screening

Every applicant is identified and screened before an account is activated.

Every applicant is identified and screened before an account is activated.

03

03

Onboarding rescreening

Onboarding rescreening

The existing customer base is automatically rescreened as sanctions lists update.

The existing customer base is automatically rescreened as sanctions lists update.

04

04

Wallet & transaction screening

Wallet & transaction screening

Deposit and withdrawal addresses are checked against sanctioned-address data.

Deposit and withdrawal addresses are checked against sanctioned-address data.

05

05

Escalation & reporting

Escalation & reporting

Confirmed matches trigger account restriction and regulatory notification.

Confirmed matches trigger account restriction and regulatory notification.

3D illustration of identifying the ultimate beneficial owner behind a corporate account structure
3D illustration of identifying the ultimate beneficial owner behind a corporate account structure

Identifying who’s actually behind an account

Identifying who’s actually behind an account

Screening a name only works if BTSE knows the right name to check. As part of onboarding, a customer identification programme authenticates and identifies retail customers directly, and — for corporate and business clients — looks through the entity to its ultimate beneficial owners, so screening is run against the people who actually control an account, not just the company name on the application.

Screening a name only works if BTSE knows the right name to check. As part of onboarding, a customer identification programme authenticates and identifies retail customers directly, and — for corporate and business clients — looks through the entity to its ultimate beneficial owners, so screening is run against the people who actually control an account, not just the company name on the application.

Wallet-level screening is what extends sanctions enforcement onto the blockchain itself: deposit and withdrawal counterparties are screened through leading blockchain analytics systems before funds move.

Blockchain analytics systems attribute sanctioned and other high-risk addresses through techniques including address clustering, open-source research, analyst review, and behavioural pattern analysis — to flag both directly designated addresses and related addresses reasonably assessed to be acting on a sanctioned entity’s behalf.

Wallet-level screening is what extends sanctions enforcement onto the blockchain itself: deposit and withdrawal counterparties are screened through leading blockchain analytics systems before funds move.

Blockchain analytics systems attribute sanctioned and other high-risk addresses through techniques including address clustering, open-source research, analyst review, and behavioural pattern analysis — to flag both directly designated addresses and related addresses reasonably assessed to be acting on a sanctioned entity’s behalf.

3D illustration of blockchain analytics tracing a wallet connection to a flagged high-risk counterparty
3D illustration of a risk signal traced across Bitcoin, Ethereum, and stablecoin transactions to a flagged address

ON-CHAIN SCREENING

Risk signals travel across chains.

3D illustration of a risk signal traced across Bitcoin, Ethereum, and stablecoin transactions to a flagged address

ON-CHAIN SCREENING

Risk signals travel across chains.

We cooperate with governments and comply with applicable regulations. If BTSE is requested for information from law enforcement authorities, we will assist and provide information where permissible by law to facilitate investigations and mitigate illicit activity.

We cooperate with governments and comply with applicable regulations. If BTSE is requested for information from law enforcement authorities, we will assist and provide information where permissible by law to facilitate investigations and mitigate illicit activity.

Check the Official Lists

Check the Official Lists

Check the Official Lists

These are the same public registers BTSE’s screening draws on — useful if you want to check a name or address independently:

These are the same public registers BTSE’s screening draws on — useful if you want to check a name or address independently:

These are the same public registers BTSE’s screening draws on — useful if you want to check a name or address independently: