Do I need a compliance officer for OFAC?

A named owner for compliance helps, but the real requirement is that screening actually runs on every payment.

TL;DR

TL;DR: OFAC does not impose a single universal rule requiring a compliance officer, but someone must own screening, and that person should ensure every payment is checked. Automating the check makes the program easier to run with a small team.

What OFAC actually requires

OFAC, the Office of Foreign Assets Control, enforces the SDN List, the Specially Designated Nationals and Blocked Persons List, with strict liability: intent is not required. The obligation is to avoid transactions with blocked parties, and a named owner is the practical way to make sure that happens.

What an owner should do

An owner confirms that screening runs in front of every payment, that data is current, and that decisions are recorded. sanctionsai.dev (agentmail) screens a counterparty before the agent pays, returning clean (ALLOW) or flagged (BLOCK) in one HTTP call under 100 ms, with data synced hourly.

Automating to lighten the load

With the 4-Gate sequence (SCREEN, SCORE, STOP, STAMP), most of the daily work is automated, so a single responsible owner can manage a small program. The free tier offers 5 checks per day with no signup and no key, and paid plans include a $10,000 legal-fee guarantee.

Sizing the role

The size of the role scales with the size of the operation. A solo builder might spend a few minutes a week reviewing automated STAMP records, while a larger team may need a dedicated hire. What matters is that someone is accountable and that the screening itself is automated and verifiable.