On September 30, 2022, the US Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) published “Sanctions Compliance Guidance for Instant Payment Systems” (the “Guidance”). The Guidance underscores the importance of a risk-based approach to managing sanctions risks related to payment technologies such as instant payment systems. The availability of funds in real time poses a challenge for financial institutions that seek to comply with US sanctions regulations. OFAC recommends that developers of instant…