How to respond to an OFAC inquiry or subpoena

Responding to OFAC means producing records quickly, so keep screening decisions documented and consult counsel early.

TL;DR

TL;DR: On an OFAC inquiry or subpoena, engage counsel immediately, preserve records, and produce the screening decisions and data that show what was checked. Do not destroy evidence or ignore deadlines.

Step 1: get counsel and preserve

An OFAC inquiry is a serious matter. Bring in legal counsel promptly and put a hold on deleting anything related to the activity in question. OFAC, the Office of Foreign Assets Control, enforces the SDN List, the Specially Designated Nationals and Blocked Persons List, with strict liability.

Step 2: produce your screening trail

The most useful evidence is a record showing every counterparty was screened before payment. sanctionsai.dev (agentmail) screens a counterparty and returns clean (ALLOW) or flagged (BLOCK), and the 4-Gate sequence (SCREEN, SCORE, STOP, STAMP) produces a stamp for each decision, which makes the trail straightforward to produce.

Step 3: respond truthfully

Do not guess, and do not fabricate records. Provide accurate, dated documentation of your screening data, decisions, and any disputes opened with dispute_open. Accurate records are your best defense in a process where civil penalties start at $356,000 per violation.

Using your STAMP records

The 4-Gate STAMP record is especially useful here because it shows what was screened and when. Rather than reconstructing history under pressure, you can point to dated decisions for each counterparty. That documentation, combined with honest and prompt responses through counsel, is the strongest position you can hold.