The desk · Last checked 12 October 2026

Accepting crypto for high-value goods? Check the payer before you release.

The short answer

Before goods leave, check three things: that the paying address and the buyer’s business are not on OFAC’s sanctions lists, that the buyer is who they say they are through a channel they did not give you, and that the payment has settled. Then release. OFAC says its sanctions liability is strict, so the record of each check matters.

Dealers in precious metals, stones and jewels above $50,000 a year in purchases and sales need a written anti-money-laundering programme (31 CFR 1027.210). For Form 8300, the IRS says businesses need not count digital assets toward the $10,000 threshold until regulations are issued; none had been issued by October 2026.

General information, not legal advice. Checked against the primary sources listed at the foot of this page on 12 October 2026. Rules change; confirm against the source before you rely on it.

What the rules expect

  • Sanctions. US persons may not deal with blocked persons or their property, including companies 50 percent or more owned by them, and must block and report blocked crypto to OFAC within 10 business days. OFAC’s 2021 guidance for the virtual currency industry calls liability strict, recommends screening customers and wallet addresses, and recommends geolocation and IP-address checks.
  • Dealer AML programme. A dealer that bought more than $50,000 and sold more than $50,000 of “covered goods” in the prior year needs a written, risk-based AML programme approved by senior management (31 CFR 1027.210). Covered goods are jewels, precious metals, precious stones, and finished goods that get at least half their value from them. Electronics are not covered. FinCEN proposed rewriting the rule on 10 April 2026, keeping the $50,000 thresholds; it is not final.
  • Form 8300. The 2021 Infrastructure Investment and Jobs Act added digital assets to the cash-reporting rule (26 U.S.C. 6050I). IRS Announcement 2024-4 says businesses need not include digital assets until Treasury and the IRS issue regulations; no such regulation had been issued by October 2026. Cash over $10,000 must still be reported.
  • Payment processors. FinCEN’s 2019 guidance treats a third-party crypto payment processor as a money transmitter. If you use one, check its FinCEN registration.

The warning signs

These are the warning signs known across the trade; none is proof on its own.

  • Urgency. Pressure to release today, or an offer to pay more for speed.
  • Someone else pays. The payer is not the buyer.
  • Refund requests. An overpayment followed by a request to send the difference back, by another method.
  • The destination moves. A change of delivery address or collector after payment.

Hold before release

  1. Know the buyerName, business, address and how they found you. For a business, check its registration and the company itself against the lists; see checking a company.
  2. Screen the addressSearch the paying address in OFAC’s Sanctions List Search ID # field, or screen against the SDN data file; see checking a wallet.
  3. Wait for settlementRelease against a settled payment, not a pending one or a screenshot.
  4. Verify by a second channelConfirm the order, the collector and the delivery address using contact details you found yourself, not the ones in the order.
  5. Release, and keep the recordThe checks, the list versions, the result, who approved release, and when.

How the desk does it

For dealers who would rather not do this alone at the counter: you send the order, the paying address and the buyer before release. We screen the address and the buyer’s business against the official lists, read the order against the warning signs above, and return GO, HOLD or a named question under written rules you own, with the record kept. We screen addresses and companies against public lists. We never trace funds to identify a person, and the release decision stays yours.

The limit, plainly. Today the check covers government sanctions lists and our public-source incident index. It is not full on-chain analytics.

Questions people ask

How do I check a crypto payment before releasing goods?
Search the paying address in the ID # field of OFAC's Sanctions List Search, check the buyer's business against the sanctions lists, verify the buyer and delivery details through contact details you found yourself, and release only against a settled payment. Keep a dated record of each check.
Do I have to file Form 8300 for crypto payments?
Not yet for the digital-asset part. The 2021 Infrastructure Investment and Jobs Act added digital assets to 26 U.S.C. 6050I, but IRS Announcement 2024-4 says businesses need not include digital assets in Form 8300 reporting until Treasury and the IRS issue regulations, and none had been issued by October 2026. Cash over $10,000 must still be reported.
Do jewellery and bullion dealers need an AML program?
A dealer that bought more than $50,000 and sold more than $50,000 of covered goods (jewels, precious metals, precious stones and finished goods deriving at least half their value from them) in the prior year must have a written, risk-based AML program under 31 CFR 1027.210. Electronics are not covered goods.
Am I liable if a sanctioned person pays me in crypto?
OFAC's guidance for the virtual currency industry says sanctions liability is strict, meaning a business can be liable even without knowing. OFAC treats a risk-based compliance program, such as screening addresses and customers, as a mitigating factor.

Primary sources

General information, not legal advice. BSJ Ventures publishes methods; it never publishes clients, cases or verdicts, and it claims no relationship with any agency or maker named here.

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The desk

Send the order before it leaves.

The paying address, the buyer and the order, checked against the official lists and the known warning signs, with a signed, dated record and the release decision left with you. Addresses and companies only; we never trace funds to identify a person.

Ask about checking crypto payers

A person reads every request and answers within a business day. Pricing is on inquiry.