On September 30, the U.S. Treasury Department’s Office of Foreign Assets Control (OFAC) published Sanctions Compliance Guidance for Instant Payment Systems, which emphasizes the importance of taking a risk-based approach to managing sanctions risks in the context of new payment technologies, such as instant payment systems, and highlights considerations relevant to managing those risks. According to OFAC, the guidance “encourages developers of instant payment systems to incorporate sanctions compliance considerations and features as they develop these systems.” The guidance, among other things, describes: (i) risk factors and considerations for instant payment systems; (ii) domestic vs. cross-border payment system; (iii) availability of emerging sanctions compliance technologies and solution; (iv) nature and value of payment; and (v) OFAC engagement and resources.