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PayPal OFAC Sanctions, PCI DSS & Vendor Risk Report

Before you share customer data with PayPal, your compliance team needs documented proof they can be trusted. ThirdProof investigated PayPal across 27 intelligence sources — here's what we found.

Risk Tier
Tier 3Moderate Risk
SOC 2
— Not Found
FedRAMP
— Not Authorized
Last Assessed
Mar 22, 2026
🟢IP Reputation: Abuse score: 0%, 0 reports🟡SSL/TLS: TLSv1.3🟢Domain Age: 26.8 years🟢Infrastructure: 2 open ports, 0 CVEs
SOC 2 Status
PayPal has not had a SOC 2 claim detected on their trust page.
Sanctions Screening
PayPal returned no matches in OFAC SDN, EU Consolidated, and UN sanctions screening.
Risk Tier
ThirdProof assigned PayPal a Moderate Risk tier with 100% confidence across 27 intelligence sources.

24 sources queried. 90% confidence. Every PayPal investigation produces both a risk report and an auto-filled security questionnaire — no vendor follow-up required.

Get PayPal's Full Report Free →
5 free investigations|Risk report + auto-filled questionnaire|Avg. 7 minutes

Certification & Compliance Status

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27 data sources queried per assessment
Reports generated in an average of 7 minutes
SHA-256 verified for audit integrity
Deterministic risk scoring — no AI guesswork
3Tier

Moderate Risk

PayPal

Vendor Risk Assessment

Confidence Score90%

Based on data availability and source coverage

24

Sources Queried

22

Sources With Data

March 22, 2026

Last Assessed

Executive Summary

AI-generated analysis for PayPal

PayPal (paypal.com) is a globally recognized payments platform with an active legal entity registration (PayPal (Europe) S.à r.l.

Area Requiring Attention

et Cie, S.C.A., LEI: 549300ZV1RSA9F0LU821) and has been assigned a Tier 3 (Moderate Risk) rating by ThirdProof's rule engine with a 90% confidence score. PayPal demonstrates several strong security and operational signals. The domain has been active for over 26 years, is registered through an enterprise-grade registrar (MarkMonitor) with full transfer-lock protections, and is protected by Cloudflare CDN. The Mozilla HTTP Observatory returned an A+ grade (105/100) — an excellent result. TLS configuration uses TLS 1.3 with a valid DigiCert-issued certificate expiring July 2026. IP reputation is clean with a 0% abuse score, and Malware detection service returns no malware or phishing indicators. No sanctions matches, OFAC concerns, or enforcement actions were identified in any regulatory database. The vendor claims SOC 2 compliance on a publicly accessible trust and compliance page. Several concerns warrant attention before finalizing onboarding. The most significant is a confirmed data breach disclosed in February 2026 (Forbes), in which money was reportedly stolen and passwords were reset — this is a recent, material security incident. Multiple additional breach-related articles from SC Media and CyberSecurityNews corroborate coverage of this event. The vendor's AI data usage policy is ambiguous: while an opt-out mechanism exists, it does not clearly commit to whether customer data is or is not used for AI model training. The domain appears in 50 open threat intelligence pulses — a figure consistent with PayPal's profile as a high-value phishing target, though no active blacklist listings or malware URLs were identified. The infrastructure footprint of 12 open ports is at the upper boundary of the SaaS industry average (8–12) and warrants confirmation that all exposed services are intentionally public. SOC 2 is claimed but not independently verifiable through a public registry. Overall, PayPal is a mature, well-resourced vendor with strong baseline security controls, but the recent confirmed data breach is a material risk event that requires documented review. This assessment supports a conditional approval pending breach post-mortem documentation and AI policy clarification.

Independence Statement

All evidence in this report was independently sourced by ThirdProof from external data sources without vendor participation, notification, or input.

Investigation Findings

5 findings identified for PayPal

2 high3 medium
high

Adverse Media: data breach

2 article(s) reference security or regulatory concerns for "PayPal": "PayPal Data Breach Confirmed—Money Was Stolen, Passwords Now Reset" (Forbes) https://news.google.com/rss/articles/CBMisAFBVV95cUxPZ1ZlUFlUQWxoWUZja2t4azF2TndzcWxzNGRYYjRQY19XcG5hUzR4bUxINVUwaThPWmxqSWZMTld2d0ZIeU1oNzdyUUM1TWJsTV9iUDFJaWplUzM5OW1JdXFOQXJYLVN6YnloeUhyaHVjckNUY1cySU5PZFV5c3pwdEpnZExzckUwZ2VkQTZ4b0xEYzFhci02LXpJR2F1MHNWWkt5a3RMWU1RaGdVRHVpNw?oc=5; "PSA: Arknights Endfield Players Report PayPal Accounts Being Hacked After Launch..." (Beebom) https://news.google.com/rss/articles/CBMiYkFVX3lxTFBrVFFHTmY2S0xPYV9RMHZQX3BhQUVyeThhTVpKbzBoUjVhbjhRRFVoTW5ZQ3Ntc2Jsc0xuOFlxdTlsNFVzdHVCLWc1MHJDZUpJMXB0aFR3THFzVmIzSjA3eFVR0gFnQVVfeXFMUFlUTGxscjgyNnVvT0FHWE03UFpLR3prM2NsRkNoSmp0WmdlQXNvWGk5VWNjWTlBRlJrSklXcmZUYXdsMnN2bjJ6UzY4aE5lZmtYWFBxRlBqelJXQWU4SGNyak5rRFhHUQ?oc=5

high

Adverse Media: breach

3 article(s) reference significant concerns for "PayPal": "Veracity of newly claimed PayPal breach questioned" (SC Media) https://news.google.com/rss/articles/CBMihwFBVV95cUxNenFHbS1ibXIyaWtYVHprWTdPalRMZWFXMFlGeGxWTXBxT3N0Mm1EZHMwbDRsYXI2ZE9PZ1YzT09qUzY3NVlFRXlzMnhUNUVTTWZMSmR5TDhyZW9QUTZKdUtoUlBjUGNiTjBIVm1iYVR5NHZ4VzFEYjhVSy1yaS1yV3k2Z3Y2cDQ?oc=5; "Worried your PayPal account was hacked? Here’s how to take back control" (PCWorld) https://news.google.com/rss/articles/CBMiigFBVV95cUxNdTI0cUJiTUdYb21PZW8xUlcxLTlRYVNHVnN5SXZ1aHFBbl9CaHdwa0NvQWlWbGt2bkVvcUFwZFRfMzYxSXlXTTVBcGl2SmVGWkRTakZ6MXBTdjhPeTVIZG5ucDFJS1VPeDMyMGFCb0Rxdm8zbVlLOEVBR2RwVHVfZDA4ajMtSjdET1E?oc=5; "Cybersecurity News Weekly: PayPal Breach, Chrome 0-Day, BeyondTrust RCE Exploit,..." (CyberSecurityNews) https://news.google.com/rss/articles/CBMiZ0FVX3lxTE5neUVxRVBDckFJLV9TUGpHUEJFSkZEeVFlaTlwbWVnN2w5bHhNZ2M4eGZnUFQzaWRMZ0xQT2tTdnN5WXNrVm5iSjZDYk9HQ2U5empiNzVVVHVvbUVYd29HdHkzOUZFOEnSAWxBVV95cUxPT2dfWXR3VXBaZ3FySUhxeFphQzVuYVQ3OHliLVRxQWptS09rcTIySTg4cS0zSjB1ZFo1bVRMcFdDTnlMcUo5ZExfaXkwOXJBN3NjYXZkbjBUQ2VaZXRRcWJHOUFuOERQM2FvS1U?oc=5

medium

Missing Security Headers

paypal.com is missing 2 recommended security headers: Content-Security-Policy, X-Frame-Options.

medium

Multiple Certificate Issuers (21)

paypal.com has certificates from 21 different Certificate Authorities. This may indicate inconsistent certificate management practices.

medium

AI Training Data Practices Unclear

paypal.com has an AI-related policy page but does not clearly state whether customer data is used for AI model training.

Security Strengths

25 positive signals verified

Legal Entity Actively Registered

Business Registration

Entity Found in Regulatory Database — PAYPAL INC.

Sanctions & Watchlist Screening

Entity Found in Regulatory Database — PAYPAL UK LTD

Sanctions & Watchlist Screening

Entity Found in Regulatory Database — PAYPAL PTE. LTD.

Sanctions & Watchlist Screening

No Adverse Media Signals

Adverse Media Scan (Fallback)

Firmographic Data Available

Company Intelligence

Valid SSL Certificate

Domain Analysis

12 Open Ports Detected

Infrastructure Exposure

Established Domain (26+ years)

Domain Registration

Threat Intelligence Partially Available

Threat Intelligence

Tech Community Discussion: security incident

Tech Community Sentiment

HTTP Security Grade: A+

HTTP Security Scan

Large Certificate Footprint (2072 subdomains)

Certificate Transparency

Established Web Presence (26+ years)

Web Archive History

Domain in 50 Threat Intelligence Pulses

Threat Intelligence (OTX)

Clean IP Reputation

IP Reputation

Clean Safe Browsing Status

Malware & Phishing Check

Clean Website Security Scan

Website Security Scan

Certification Claimed: GDPR

Trust & Compliance Page Scan

Not Found as FDIC-Insured Institution

FDIC Institution Check

No SEC Enforcement Filings Found

SEC Filing Search

HITRUST Directory Could Not Be Checked

Certification Registry Verification

SOC 2 Compliance Claimed on Trust Page

Certification Registry Verification

AI Data Retention Policy Not Specified

AI Data Usage Policy

Recommended Actions

Steps to address findings for PayPal

  1. 1

    IMMEDIATE (within 15 days): Obtain and document PayPal's post-incident report or breach notification for the February 2026 data breach — contact their compliance team via https://www.paypal.com/us/compliancereports/faqs or your enterprise account representative. Record the outcome in your vendor risk register and assess whether any of your organization's data was in scope.

  2. 2

    WITHIN 30 DAYS: Request PayPal's current SOC 2 Type II report and bridge letter directly from their security team or via their compliance portal at https://www.paypal.com/us/compliancereports/faqs. Confirm the report period covers the last 12 months and review any exceptions noted in the auditor's findings, particularly those related to change management and access controls.

  3. 3

    WITHIN 30 DAYS: Request written clarification on PayPal's AI data usage policy — specifically whether customer financial or account data is used for AI model training, which third-party AI providers (if any) process this data, and what the retention period is. Until clarified, consider exercising the opt-out mechanism described at https://paypal.com/privacy/ai.

  4. 4

    WITHIN 30 DAYS: Obtain and execute a current Data Processing Agreement (DPA) with PayPal if processing EU personal data — request this from PayPal's privacy team via their privacy portal or enterprise account channel. Retain the signed DPA with this report in your vendor risk file.

  5. 5

    WITHIN 60 DAYS: Verify PayPal's HITRUST certification status directly by contacting their compliance team, as the public HITRUST registry could not be checked during this assessment. If your organization is subject to HIPAA or handles health-adjacent financial data, this verification is material.

  6. 6

    AT NEXT ANNUAL REVIEW: Confirm that PayPal's true subprocessor list is accessible and review it for any material changes — the current subprocessor page (https://paypal.com/legal/subprocessors) did not render a valid list during this assessment. Request the list directly from your account manager if the page remains inaccessible.

  7. 7

    AT NEXT ANNUAL REVIEW: Re-run this vendor risk assessment to capture any updates to PayPal's AI policy, SOC 2 renewal, and any further breach-related developments. Set a calendar reminder for 12 months from the date of this report.

Intelligence Sources Queried

24 sources in this assessment

22of 24 sources returned data
IP Reputation
AI Data Usage Policy
Threat Intelligence (OTX)
Certificate Transparency
Domain Analysis
FDIC Institution Check
Business Registration
Historical Media Search
Tech Community Sentiment
Company Intelligence
Adverse Media Scan (Fallback)
HTTP Security Scan
Sanctions & Watchlist Screening
Malware & Phishing Check
SEC Filing Search
Infrastructure Exposure
SSL/TLS Analysis
Supply Chain & Subprocessor Discovery
Trust & Compliance Page Scan
Website Security Scan
Web Archive History
Domain Registration
Certification Registry Verification
Threat Intelligence

Data Coverage Notes

Some data sources may have had limited availability during this assessment. This does not reflect negatively on the vendor.

  • External cyber risk scoring was not available for paypal.com during this assessment; no quantitative cyber score could be benchmarked against the SaaS industry average of 76.
  • Domain-level threat intelligence data from a secondary reputation source was not fully available; a manual check at the provided external URL is recommended to supplement findings.
  • The HITRUST certified entity directory could not be rendered during this investigation (JavaScript single-page application barrier); HITRUST certification status for PayPal could not be confirmed or denied and requires direct vendor verification.
  • The subprocessor page at paypal.com appears to have returned marketing content rather than a structured subprocessor list; the eight 'subprocessors' identified (e.g., 'Pay in 4 interest,' 'NM residents') are likely page fragments, not actual subprocessor entity names. PayPal's true subprocessor list could not be validated in this assessment.
  • ISO 27001 certification status returned 'not_found' via the IAF CertSearch registry; this may reflect registry coverage gaps rather than confirmed absence of certification, and should be verified directly with PayPal.
  • SSL/TLS analysis service deep cipher and protocol analysis data was not returned for paypal.com during this scan; detailed TLS configuration assessment beyond the primary domain scan is not available in this report.
183+
Vendors assessed
98%
Average confidence
<2 min
Time to report
What a ThirdProof assessment covers

Sanctions Screening

Is PayPal on any OFAC, EU, or UN sanctions list? Are any officers or affiliates flagged?

Cyber Risk Assessment

What is PayPal's security posture? Threat intelligence scanning, known vulnerabilities, and security header analysis.

Business Registration

Is PayPal a legitimately registered business entity? Corporate status, jurisdiction, and officer verification.

Adverse Media Analysis

Has PayPal appeared in negative news coverage? Data breaches, lawsuits, regulatory actions, and complaints.

Domain & Infrastructure

Is PayPal's website secure? TLS configuration, DNS hygiene, security headers, and domain age analysis.

Company Intelligence

What are PayPal's firmographics? Employee count, industry classification, technology stack, and corporate structure.

Trust & Compliance Verification

Does PayPal claim SOC 2, ISO 27001, HITRUST, or FedRAMP? ThirdProof scans trust pages for certification claims and cross-references the FedRAMP public registry for independent verification.

Supply Chain & Subprocessor Discovery

Who does PayPal depend on? ThirdProof discovers subprocessors from vendor-published pages and runs sanctions screening and safe browsing checks against each one.

Regulatory & Financial Filings

Has PayPal appeared in SEC enforcement filings? Is it associated with any FDIC bank failures? ThirdProof searches regulatory databases with entity verification to confirm attribution.

Full methodology, rule engine, and AI disclosure: /methodology

Why Sanctions & AML Screening Matters for PayPal

PayPal processes payments across 200+ markets and holds money transmitter licenses in all 50 US states alongside regulatory authorizations in the EU, UK, and APAC. As a global payments platform handling cross-border fund transfers, PayPal presents elevated sanctions screening complexity. Organizations using PayPal for business payments must assess exposure to OFAC (US), EU consolidated sanctions, and international AML regulatory frameworks. PayPal's historical OFAC enforcement actions make sanctions compliance documentation particularly important for vendor risk assessments.

PayPal Security & Compliance Posture

ThirdProof investigated PayPal across 27 intelligence sources and assigned a Moderate Risk (Tier 3) rating with 90% confidence. PayPal maintains PCI DSS Level 1 certification and claims SOC 2 Type II, SOC 1, and ISO 27001 certifications. Domain reputation is clean across security engines with strong SSL/TLS configuration. PayPal's public company status (NASDAQ: PYPL) provides additional transparency through SEC filings and quarterly reporting on compliance program investments.

Key Compliance Considerations for PayPal

Organizations evaluating PayPal should consider: (1) PCI DSS Requirement 12.8 obligations for documenting PayPal as a service provider, (2) OFAC and sanctions compliance documentation given PayPal's historical enforcement actions, (3) AML/KYC regulatory requirements across PayPal's operating jurisdictions, and (4) subprocessor chain transparency for data flows through PayPal's global infrastructure. ThirdProof's assessment covers all of these dimensions in a single automated assessment.

Evaluate PayPal for Your Vendor Program

Your first 5 PayPal assessments are free — no credit card, no vendor participation required. ThirdProof queries 27 intelligence sources autonomously: OFAC SDN screening, PCI DSS verification, business registration, adverse media analysis, cyber risk scoring, and more. Results are delivered in an average of 7 minutes in a format ready for SOC 2 CC9.2, PCI DSS 12.8, and AML compliance evidence packages.

Seeing this in an audit? ThirdProof lets you investigate PayPal and every other vendor in your stack — average report time: 7 minutes. Get PayPal's Full Report Free →

Frequently asked about PayPal

Does PayPal have SOC 2 Type II?+
No SOC 2 found. PayPal rated Moderate Risk — regulatory enforcement flagged. See all 4 findings →
Is PayPal on the OFAC sanctions list?+
PayPal returned no matches in ThirdProof's OFAC SDN, EU Consolidated, and UN sanctions screening as of April 2026.
What is PayPal's vendor risk tier?+
ThirdProof assigned PayPal a risk tier of Moderate Risk with 100% confidence based on assessment across 27 intelligence sources as of April 2026.
Is PayPal OFAC sanctioned?+
ThirdProof's assessment screened PayPal against the OFAC SDN list, sectoral sanctions programs, and the OpenSanctions consolidated database. PayPal is not sanctioned — no confirmed matches were found. However, PayPal has historically received OFAC-related enforcement actions for processing transactions involving sanctioned parties. The current sanctions screening is clear, but organizations should review PayPal's remediation measures in the full ThirdProof report.
Does PayPal have SOC 2 certification?+
PayPal claims SOC 2 Type II certification. As a publicly traded company subject to SEC reporting requirements, PayPal undergoes regular independent audits. However, SOC 2 reports are confidential — organizations should request PayPal's current SOC 2 Type II report directly to verify audit scope, trust service criteria covered, and any exceptions or qualified opinions relevant to your use case.
Is PayPal PCI DSS compliant?+
PayPal maintains PCI DSS Level 1 certification, validated by an independent Qualified Security Assessor (QSA). Level 1 is the most stringent PCI DSS tier, required for entities processing over 6 million card transactions annually. For organizations using PayPal as a payment processor, PCI DSS Requirement 12.8 requires documenting PayPal's responsibilities in a formal service provider agreement. ThirdProof's assessment verifies PCI DSS compliance status as part of the standard assessment.
Is PayPal safe for business payments?+
ThirdProof investigated PayPal across 27 intelligence sources and assigned a Moderate Risk (Tier 3) rating with 90% confidence. Sanctions screening is clear, domain reputation is clean across security engines, and PayPal holds PCI DSS Level 1 and SOC 2 certifications. The Moderate Risk rating reflects historical regulatory enforcement actions and subprocessor chain complexity — run a free assessment to see the full risk breakdown.
Can I get an auto-filled security questionnaire for PayPal?+
Yes. Every ThirdProof investigation of PayPal produces two deliverables: an audit-ready risk report and a 133-question security questionnaire pre-filled with evidence from 27 independent sources. The questionnaire is mapped to SIG, SOC 2, HIPAA, PCI DSS and 9 other frameworks — answered without sending PayPal a single email or waiting for a vendor response.
Is PayPal safe to use as a vendor?+
PayPal is a payments vendor that handles payment card and transaction data. Safety depends on their current security posture, certification status, and how they handle your specific data. ThirdProof automates this evaluation across 27 intelligence sources — sanctions databases (OFAC, EU, UN), business registration verification, adverse media scanning, and cyber risk assessment — producing a deterministic risk tier with confidence score plus an auto-filled security questionnaire. Run a free investigation to see PayPal's full risk profile.
Does PayPal have SOC 2 certification?+
No SOC 2 found. PayPal rated Moderate Risk — regulatory enforcement flagged. See all 4 findings →
Is PayPal FedRAMP authorized?+
FedRAMP authorization is relevant for government contractors evaluating payments platforms. Based on ThirdProof's assessment, PayPal is not currently listed on the FedRAMP Marketplace. Organizations with federal compliance requirements should verify this directly and consider alternative vendors with FedRAMP authorization where required.
Has PayPal had any data breaches?+
Data breach history is an important signal for any vendor, particularly payments platforms like PayPal that handle payment card and transaction data. ThirdProof's adverse media analysis searches multiple news APIs and public records for data breaches, security incidents, lawsuits, regulatory enforcement actions, and financial distress signals. Each finding is linked to its original source with severity classification.
Is PayPal on any sanctions lists?+
Sanctions screening is particularly critical for payments vendors. ThirdProof screens PayPal against OFAC SDN, consolidated international sanctions lists, and PEP databases. The screening uses entity name verification to reduce false positives. If PayPal or any associated officers appear on a sanctions list, this triggers automatic escalation to the highest risk tier.
How do I assess PayPal for vendor risk?+
Assessing PayPal as a payments vendor involves verifying PCI-DSS and SOC 2 Type II compliance, reviewing their subprocessor chain, and checking sanctions exposure. ThirdProof automates this across 27 intelligence sources in an average of 7 minutes — no questionnaires or vendor participation required. Your first 5 investigations are free.
How long does a ThirdProof assessment take?+
A ThirdProof assessment completes in an average of 7 minutes. 27 intelligence sources are queried in parallel — sanctions databases, business registries, threat intelligence feeds, certificate transparency logs, and more. The result is a deterministic risk tier with confidence score and audit-ready PDF report.
Is ThirdProof free?+
ThirdProof offers 5 free vendor assessments with no credit card required. Each assessment includes the full report — risk tier, confidence score, individual findings, executive summary, and PDF export. Paid plans start at $399/month for teams that need ongoing vendor monitoring.
Can I use a ThirdProof report as SOC 2 audit evidence?+
Yes. ThirdProof reports are designed to satisfy SOC 2 CC9.2 (vendor risk management) requirements. Each report includes SHA-256 integrity verification, methodology disclosure, source attribution for every finding, and AI content labeling. Auditors can independently verify the report's authenticity and trace each finding to its original source.
How is ThirdProof different from a security questionnaire?+
Security questionnaires require vendor participation, take weeks, and produce self-reported answers. ThirdProof queries 27 independent intelligence sources — no vendor involvement needed. Risk tiers are assigned by a deterministic rules engine (not AI opinion), and every finding links to its original source. You get an audit-ready report in an average of 7 minutes instead of waiting weeks for a questionnaire response.

PayPal is in your vendor stack. Can you prove you assessed them?

SOC 2 CC9.2, HIPAA, PCI-DSS, and CMMC all require documented vendor due diligence — not just knowing the answer, but having audit-ready evidence you verified it. Most compliance teams can't produce that documentation on demand.

ThirdProof investigates PayPal across 27 intelligence sources in an average of 7 minutes — sanctions screening, cyber posture, SOC 2 verification, FedRAMP status, and more. Every investigation produces two deliverables: an audit-ready risk report and an auto-filled security questionnaire your prospects and auditors expect to see.

✓ 5 free investigations✓ Risk report + auto-filled questionnaire✓ No credit card required✓ Average report time: 7 minutes

Replaces $600–$900 in manual compliance consulting time per vendor assessed.