Compliance Checkpoints
Where obligations fire
in the payment lifecycle.
The big picture: Every stablecoin transaction passes through compliance gates — screening, monitoring, and filing obligations — mapped to the eight stages of the Stable straight-through processing (STP) model. Each checkpoint is classified by stage position, legal basis, and tooling.
Select a stage to explore
Intent
The Mandate Gate
"Who holds the mandate to make this happen?"
Compliance Gates
Sanctions screening
Legal basis
OFAC SDN, EU consolidated list
Tools
Chainalysis, Elliptic, TRM Labs
PEP screening
Legal basis
AML/CFT directives, local PEP lists
Tools
ComplyAdvantage, Dow Jones
Checkpoint Density
Compliance Tags
FATF Recommendations
R.1 — Risk Assessment
Risk-based approach — assess ML/TF risk before onboarding
R.6 — Targeted Financial Sanctions
Screen against UN/national sanctions lists at first contact
Checkpoint Density
Where compliance obligations concentrate
Why it matters: Not all stages carry equal compliance weight. Identity and Facilitation are the most gate-heavy stages. Finality carries the most filing obligations. This chart shows the distribution of gates, monitors, and obligations across all eight stages.
AML / CFT Framework
The regulatory foundation
What it is: Compliance checkpoints derive from a layered regulatory architecture — global standards (FATF), national AML acts, and counter-financing of terrorism (CFT) obligations. Each layer maps to specific stages in the payment lifecycle.
FATF 40 Recommendations
The global standard for AML/CFT. Key recommendations map directly to STP stages: R.10 (CDD) → Identity, R.16 (Travel Rule) → Transport, R.20 (STR) → Finality. The June 2023 updated guidance explicitly covers virtual assets and VASPs.
R.1→Intent · R.10→Identity · R.16→Transport · R.20→Finality · R.29→Finality
Jurisdiction AML Acts
National implementations vary in scope and threshold. BSA (US) sets $5K SAR / $10K CTR thresholds. MLD6 (EU) harmonizes across 27 member states. POCA (UK) uses a consent-based regime. PSA (Singapore) regulates digital payment tokens under MAS.
BSA→US · MLD6→EU · POCA→UK · PSA→SG · AMLO→HK · JFSA→JP
CFT Framework
Counter-financing of terrorism obligations include UNSCR-mandated sanctions, OFAC designations, and EU restrictive measures. Freezing workflows fire at Authorization (real-time block) and Facilitation (settlement hold). Asset freeze functions are built into major stablecoin smart contracts.
Sanctions→Intent · Freezing→Authorization · STR filing→Finality
Stablecoin Typologies
Common ML/TF patterns: layering through DeFi protocols (detectable at Transport), chain-hopping via cross-chain bridges (Facilitation), nested service provider abuse (Identity), and rapid conversion (Finality). Jurisdiction-specific red flag indicators inform monitoring rules.
Nested services→Identity · DeFi layering→Transport · Chain-hopping→Facilitation
Jurisdiction Coverage
AML/CFT acts by jurisdiction
Methodology
How checkpoints are mapped
How it works: Each checkpoint is classified across three dimensions: stage position (where in the lifecycle), legal basis (the regulation requiring the check), and tooling (solutions used to satisfy the requirement).
Sources: Classification follows FATF guidance (40 Recommendations, June 2023 VA/VASP update), jurisdiction-specific AML/CFT acts, and issuer compliance documentation.
Go deeper: The Stable STP model provides the stage framework. See StableSTP.com for the full specification. For jurisdiction-specific detail, see the Travel Rule map and individual jurisdiction pages.