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OFAC SCREENING ACTIVE

Sanctions Compliance Framework

Stripe-Delegated Sanctions Compliance with supplementary platform controls, immutable audit logging, and GDPR/CCPA-compliant data handling.

Stripe-Delegated Sanctions Compliance

exact.works delegates primary sanctions screening to Stripe, our payment processor. Stripe maintains comprehensive OFAC compliance programs and performs identity verification on all connected accounts. exact.works supplements this with additional platform-level controls to catch obvious bad actors before they reach Stripe onboarding.

Stripe Connect StandardOFAC SDN ScreeningImmutable Audit Trail

Reference Documentation

Full compliance details are documented in our Platform Terms of Service, Section 1.8:

# Section 1.8 - OFAC and Sanctions Compliance
Platform Terms of Service v7 defines exact.works' sanctions compliance framework, including Stripe delegation, screening tiers, data retention, and user obligations.

4-Tier Screening Architecture

Defense-in-depth compliance controls

exact.works implements a multi-layered compliance architecture where Stripe serves as the primary screening authority, supplemented by platform-level controls at each stage of the seller onboarding and transaction lifecycle.

Tier 1

Documentation

Stripe is documented as the primary sanctions screening provider in our Terms of Service.

  • Terms of Service Section 1.8
  • Stripe Connect Standard integration
  • Delegated KYC/KYB responsibility
  • Clear user disclosure requirements
ACTIVE
Tier 2

Pre-Onboarding Screen

Lightweight OFAC SDN check at account creation to catch obvious bad actors before Stripe.

  • OFAC SDN list screening (daily refresh)
  • Name normalization and token matching
  • Blocks obvious matches before Stripe onboarding
  • Matches flagged for manual review
ACTIVE
Tier 3

Compile-Time Verification

Stripe account status verified at execution time for every transaction.

  • charges_enabled status verified
  • Disabled accounts blocked from execution
  • Real-time Stripe API integration
  • Prevents transactions with restricted accounts
ACTIVE
Tier 4

Immutable Audit Trail

Every screening event logged permanently in the SanctionsScreening table.

  • Records NEVER deleted (regulatory evidence)
  • User ID, screened names, results logged
  • IP addresses retained for 90 days (GDPR)
  • Supports regulatory audits and investigations

OFAC SDN Screening

Specially Designated Nationals List

Our Tier 2 screening checks names against the U.S. Treasury's OFAC Specially Designated Nationals (SDN) list. This is a supplementary check designed to catch obvious matches before they reach Stripe's more comprehensive screening.

Data Source

Treasury.gov SDN CSV

Official OFAC SDN list downloaded directly from the U.S. Department of the Treasury website.

Refresh Frequency

Daily at 2:00 AM UTC

Automated cron job refreshes the SDN data daily with atomic pointer swap for zero-downtime updates.

Storage

Vercel KV (Edge)

SDN data stored in Vercel KV for low-latency serverless access with version control.

Matching Algorithm

1
Exact Match: Normalized name matches SDN entry exactly
2
Single Token: Input is a single token (5+ chars) that matches an SDN name
3
SDN Subset: All SDN tokens appear in the input name
4
Intersection: Two or more tokens match between input and SDN name

Data Retention & Privacy

GDPR/CCPA Compliance

exact.works balances regulatory evidence requirements with data minimization principles. SanctionsScreening records are retained permanently for compliance, but personally identifiable information is minimized according to GDPR/CCPA.

IP Address TTL

IP addresses in SanctionsScreening records are automatically nullified after 90 days. A daily cron job at 3:00 AM UTC handles this cleanup.

Retention Period:90 days
Cleanup Schedule:Daily 3:00 AM UTC
Action:SET ipAddress = NULL

Permanent Records

Screening records themselves are NEVER deleted. They serve as regulatory evidence that compliance checks were performed.

Record Retention:Permanent
User ID:Retained
Screened Names:Retained

Data Subject Rights

While screening records cannot be deleted due to regulatory requirements, users may request access to their screening history and the personal data we hold. Contact [email protected] for data access requests.

Audit Log Contents

SanctionsScreening Record Fields

Every screening event creates an immutable record in the SanctionsScreening table. These records support regulatory audits and demonstrate due diligence.

FieldTypeDescription
idStringUnique screening event ID
userIdStringUser being screened
screenedNameStringName that was screened
screenedEntityString?Entity name (if applicable)
screenTypeEnumACCOUNT_CREATION, TRANSACTION, MANUAL
screenMethodStringOFAC_KV_CHECK, STRIPE_STATUS, etc.
resultEnumCLEAR, POTENTIAL_MATCH, ERROR
matchDetailsJSON?Match information if flagged
ipAddressString?IP address (nullified after 90 days)
screenedAtDateTimeTimestamp of screening

Enterprise Security Controls

F500-grade security infrastructure

exact.works implements defense-in-depth security controls designed to meet the requirements of Fortune 500 procurement teams and enterprise security reviews.

Encryption at Rest

All data stored in exact.works is encrypted at rest using AES-256. Database encryption is provided by Supabase infrastructure with customer-managed encryption keys available for enterprise plans.

Algorithm:AES-256-GCM
Provider:Supabase (PostgreSQL)
Key Management:AWS KMS

Security Headers

All responses include security headers protecting against common web vulnerabilities.

CSP:Enforced
HSTS:max-age=31536000
X-Frame-Options:DENY
Permissions-Policy:Restrictive

Audit Logging

All state-mutating operations are logged to an immutable audit trail with user context, timestamps, and action details.

Logged Actions:All mutations
Retention:7 years
Export:JSON, CSV

Data Access Logging

HIPAA-pattern access logging tracks all data access during agent execution. Buyers can review exactly what data was accessed.

Exhibit Access:Logged
Secret Access:Logged
API Calls:Logged

Enterprise SSO

AVAILABLE ON REQUEST

SAML 2.0 and OIDC single sign-on integration is available for enterprise customers. Contact our sales team to configure SSO with your identity provider (Okta, Azure AD, Google Workspace, etc.).

SAML 2.0OIDCSCIM Provisioning

Contact [email protected] to discuss enterprise SSO requirements.

Questions?

For questions about our compliance framework or to report a concern:

[email protected]Back to Trust Center
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