DATABASE//LEGAL-COMPLIANCE//STABLECOIN B2B PAYMENTS: NAVIGATING KYC/AML FOR NON-FINANCIAL ENTITIES

Module Execution // LEGAL & REGULATORY / AML & SANCTIONS

Stablecoin B2B Payments: Navigating KYC/AML for Non-Financial Entities

REF_ID: LSSN_STABLECO

LAST_AUDIT: January 6, 2026

EST_TIME: 14 Minutes

REFERENCE_NOTE

The Executive Verdict

What are the KYC requirements for a US company paying international vendors in USDT? The Verdict: Non-financial entities are NOT required to perform BSA-level KYC on every vendor. You are not a bank. However, you MUST perform Sanctions Screening (OFAC). • KYC: Voluntary (unless you are a Money Transmitter). • Sanctions: Mandatory Strict Liability. You cannot pay a wallet on the SDN list. Risk: If you pay a sanctioned entity, you are liable even if you didn't know.

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1. The Core Definition: Non-Financial Entity Obligations

In traditional banking, the bank screens the recipient. In Web3, YOU are the bank. You inherit the screening obligation. If you send USDC from a self-hosted ledger, you must verify the destination.

VISUAL_RECON

A "Responsibility Shift" diagram. Top half (Fiat Wire): Screening burden on Bank. Bottom half (Stablecoin Tx): Screening burden on Corporate Sender.

Architectural Wireframe // CW-V-001

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2. OFAC Strict Liability: The Invisible Electric Fence

"Strict Liability" means ignorance is not a defense. Tainted Wallet Risk: It's not just who you pay, but where the wallet has been (Mixers, Darknet). Action: Screen every address before authorizing payment.

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3. The Money Transmitter Trap: When Do You Become an MSB?

Threshold: Paying your own bills = User (Exempt). Paying on behalf of others = Money Transmitter (Regulated). Regulation: FinCEN Guidance FIN-2019-G001. Strategic Advice: Keep treasury operations strictly proprietary.

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4. Operational Protocol: Sanction Screening Workflow

1. Whitelisting Request (Vendor submits address). 2. Automated Screening (Chainalysis/TRM/Elliptic). 3. Penny Test Confirmation (Send $10 to verify control).

Stop Reading, Start Building

Theory is dangerous without execution.

Tagging Taxes in QuickBooks & KYC Checklists. Watch the step-by-step video guide in the The Compliance Course ($49).

VISUAL_RECON

A flowchart titled "The B2B Stablecoin Payment Gate." Steps: Invoice -> OFAC Check -> Penny Test -> Bulk Payment.

Architectural Wireframe // CW-V-001

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5. The Travel Rule: Data Transmission Obligations

Technically applies to VASPs, but impacts you when sending to exchanges. Missing data (Originator/Beneficiary info) can freeze funds at the receiving exchange. Best Practice: Include invoice ref/memo.

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6. Vendor Onboarding: The "Crypto W-9"

Require enhanced data: Wallet Address, Wallet Type (Custodial/Self-Hosted), Token Contract Address (ERC-20 check), and Beneficiary Jurisdiction. Table: Risk Scoring Your Vendors (Public Corp = Low, Unknown Wallet = High).

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7. Compliance Tech Stack: Tools of the Trade

Wallet Screening: Chainalysis KYT, TRM Labs. Transaction Monitoring: Merkle Science. Identity Verification (KYB): Sumsub, Persona. Don't build this; buy enterprise grade.

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8. Summary Checklist: The "Safe Send" Protocol

1. Sanctions Check Passed. 2. Test Transaction Verified. 3. Network Match Confirmed. 4. Memo/Tag Included.

F.A.Q // Logical Clarification

If I use Coinbase Prime, do I need to screen?

"Yes. Coinbase screens for their liability, not yours. You are still responsible for your business instructions."

Can I use Privacy Coins (Monero)?

"No. Immediate "Red Flag" for money laundering. Virtually guarantees an audit."

What if a vendor has no physical address?

"Do not pay them. A wallet is not an identity. Requires KYB."

Official Training Material

Master The Process

You've read the theory. Now master the execution. Get the complete The Compliance Course tailored for this exact framework.

INCLUDES: VIDEO TUTORIALS • TEMPLATES • SOP CHECKLISTS

Module ActionsCW-MA-2026

Institutional Context

"This module has been cross-referenced with Legal & Regulatory / AML & Sanctions standards for maximum operational reliability."

VECTOR: LEGAL-COMPLIANCE

STATUS: DEPLOYED

REVISION: 1.0.4