As a U.S.-based company operating globally, Upwork maintains a global sanctions compliance program designed to meet its obligations under applicable laws and regulatory standards worldwide. In addition to regulations administered by OFAC, our screening processes align with international restrictions, including those issued by the European Union (EU), United Kingdom (UK), and the United Nations Security Council (UN).
Sanctions may also affect Upwork's ability to provide services in certain locations. For information about geographic availability, see Who's eligible to join and use Upwork? in the Upwork Help Center.
Note:
Sanctions programs can change in response to government actions, legislation, and geopolitical events. Individuals, organizations, countries, and regions can be added to or removed from sanctions programs over time.
As a result, Upwork may update its compliance requirements or the availability of its services when necessary.
What is sanctions screening?
Sanctions are legal and economic restrictions set by governments and official authorities. They may prohibit or limit certain transactions or business relationships involving particular individuals, organizations, governments, countries, or regions.
To comply with these requirements and keep our platform secure, Upwork conducts routine sanctions screening. This process checks account details against official restrictions, such as those managed by the U.S. Department of the Treasury’s Office of Foreign Assets Control, known as OFAC.
By maintaining these compliance standards, we help create a safe, trusted marketplace for clients and freelancers worldwide.
Why does Upwork conduct sanctions screening?
Sanctions screening helps Upwork identify situations where providing services, processing transactions, or maintaining a business relationship may be prohibited or restricted by law.
This process protects the integrity of our marketplace and ensures our platform remains a safe, secure environment for clients and freelancers worldwide.
What is a Sanctions alert?
A sanctions alert - which is sent to the Trust & Safety Team, means that some information associated with your account “may” be similar to information associated with a sanctioned individual or entity and requires additional review. Upwork must then conduct further assessments to validate if you or your information matches that of a sanctioned person or entity before you can proceed further on the platform.
An alert is not, by itself, a determination that you or your business is sanctioned.
I’ve been on the platform for years, why am I only now being flagged?
Names and entities are constantly being added to screening watchlists. These are controlled by international governments and not Upwork. As a result, if your information matches that of a newly added entity, your account may be flagged for further assessment.
Why can sanctions screening generate a potential match?
Sanctions lists can contain names and other information that are the same as or similar to information belonging to people and businesses that are not sanctioned.
For example:
- Multiple people may share the same or similar names.
- A person may use initials or abbreviated information that provides less detail to distinguish them from someone else.
- Different businesses may have similar names.
- Generic business names may contain words that also appear in the names of sanctioned organizations.
Because of these similarities, sanctions screening may identify information that requires additional review to determine whether it actually relates to a sanctioned party.
What happens if I receive a sanctions alert?
If you receive a sanctions alert, we may review additional information to determine whether the sanctions restrictions apply to you or your business.
In some cases, we may ask you to verify information associated with your account. This can help distinguish you from another person or organization with similar information.
Depending on the circumstances, some account functionality may be temporarily limited while the review is completed.
If we request information or verification from you, follow the instructions provided by Upwork via email or notifications in your profile. Provide accurate and complete information as quickly as possible to help us complete the review.
Keep your information secure:
- Only provide personal or sensitive information through official Upwork channels. Do not post identity documents or other sensitive information publicly or send them to another Upwork customer.
- Don’t create a new account or provide inaccurate identity, business, or location information to try to avoid a sanctions review. If information on your account is inaccurate, update it so that it correctly reflects your identity or business.
How can I help avoid unnecessary reviews?
You can help reduce unnecessary delays or reviews by keeping your Upwork account information accurate, complete, and specific. When updating information, make sure to update both your account name, and payment methods (such as credit card holder name):
- Use your full legal name. Enter your complete legal name as it appears on official identity documents rather than initials (e.g. enter "John Doe" instead of “J D”). Rest assured, to protect your privacy, other customers are only able to see your first name and the first initial of your last name.
- Ensure name consistency across payment methods. Make sure your legal name on Upwork matches the name on your payment and withdrawal instruments (e.g., credit card or bank account holder name). Mismatches between your profile name and payment details can trigger secondary compliance reviews.
- Provide your actual business name. Use your business's registered legal or commonly used business name. Avoid generic placeholders such as "Company," "Private," or "Confidential”. Generic names provide less information to distinguish your business from other organizations and increase the likelihood of automated screening flags.
- Keep your location and other account information current. Accurate and up-to-date information can help distinguish your account from other individuals or businesses with similar information.
- Complete verification requests when Upwork asks you to do so. Additional verification may help resolve uncertainty when account information is similar to information associated with another person or organization.
- Use official Upwork channels when submitting documents or sensitive information. If we ask for identity documents or other sensitive information, use the secure method we provide.
- Don’t conceal or misrepresent your identity, business information, or location. This is a direct violation of our Terms of Service and may lead to your account being suspended.
How does Upwork protect my information?
Compliance reviews may require Upwork to evaluate information associated with your account. Upwork handles personal information in accordance with its Privacy Policy and applicable law. For security and compliance reasons, we don’t disclose detailed screening criteria or internal review procedures.