I can’t remember the last time I entered a description of a Venmo transaction that wasn’t a dumb joke, and if you use the service regularly, I doubt you can either. The ability to pay a friend back for pizza and call it “anthrax” is part of the financial app’s charm. But joking about certain places, people, or things could put you under investigation.
Within the Treasury Department is Office of Foreign Assets Control (OFAC), an entity that essentially makes sure Americans aren’t sending money to terrorist organizations and enemy regimes. For example, if you try to PayPal money to Syrian president Bashar al-Assad, OFAC is there to block it. And this applies to anything Treasury defines as a “Money Service Business,” which includes apps like Venmo. So: everything you do on Venmo is subject to scrutiny and federal compliance. Even the handjob and anthrax jokes.
One Venmo user was startled when he found this out firsthand, four months after he completed a Venmo transaction for “iced coffee obama nsa inside job syria.” This was no laughing matter (I’ve redacted his name at the request of an intermediary who provided me with the email):
How did something so obviously facetious trigger a federally mandated review? I talked to a Venmo spokesperson, who explained that the company searches everything you write in the app against a database of keywords, flagging anything that might run afoul of U.S. sanctions abroad.
One source of keywords is the Specially Designated Nationals and Blocked Persons list (“SDN List”), which cites entities that are forbidden. This could be bad news if you plan on using Venmo with anyone who has an even vaguely Middle Eastern name, as at least one user has learned in the past. Aside from flagging anything like Omar, Mohammed, Sharif, Ahmed, and the like, Venmo will flag posts that mention any country sanctioned by the United States. If you write “Syria” in a Venmo transaction, someone is going to read it.
The rest of Venmo’s red flag database is drawn from a large list of other American sanction programs, much broader than specific individuals. A Treasury spokesperson told me that they don’t provide provide anyone with a specific set of keywords to watch—rather, companies like Venmo create such a list on their own based on a list of sanctioned people, places, and entities. How to comply with OFAC is ultimately up to Venmo. But it’s safe to say that any nouns related to drug cartels, cybercrime, Iran, Iraq, Libya, terrorist organizations, Burma, Sudan, Somalia, North Korea, or any other real and perceived enemies of the state.
But what about the fact that something like “iced coffee obama nsa inside job syria” was very obviously a joke? Don’t expect Venmo to give you the benefit of the doubt: “We know that our user base has a tendency to use of humor for payments, however when that is the case, and our compliance teammates are reviewing that, we can’t make an assumption.” So, “iced coffee obama nsa inside job syria” could be an attempt to fund a Syrian death squad for the amount of five dollars. And if you don’t respond with a detailed explanation of what “iced coffee obama nsa inside job syria” really means? Eventually, Venmo told me, after repeated attempts to contact you, they’d have to turn the case over to the federal government.
So although the odds of winding up in a CIA blacksite because you paid your roommate back for rent as “tehran dirty bomb cocaine” are relatively low, just know that there is an entire team dedicated to reading and vetting your jokes on Venmo. The company wouldn’t tell me exactly what words they’re looking for, obviously, but between this and this you should have a good idea. And for the terrorists and money-launderers out there, just label all your Venmo transactions “movie tickets” and it’ll be smooth sailing.