By · · last updated 2026-08-08
OFAC's Framework for Compliance Commitments: management commitment, risk assessment, internal controls, testing, and training. What each pillar means for agent deployments.
OFAC's Framework for Compliance Commitments describes the five pillars of a compliance program. For agent operators, each pillar has a specific technical shape.
Senior management buys in and designates a compliance owner. For an agent deployment: someone owns the payment path and its screening.
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Identify where the risk lives: products, counterparties, geographies, and - for agents - autonomy level. The risk assessment template turns it into a scored document.
Screen before sign, fail closed, no override path. This is the pillar with the most technical surface - and the one screening implements.
Verify the controls work: test with known sanctioned wallets, review the logs, run the regulator-readiness drill quarterly.
The people around the agent understand the program. For autonomous deployments, the training is partly encoded: the agent's own rules.
OFAC treats a documented program as a mitigating factor. The five pillars are also the answer an inquiry demands - see the inquiry scenario.
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