Is Sanctions Screening Required for AI Agents?

The direct answer on whether AI agents require sanctions screening.

TL;DR

TL;DR: If your agent can move money, screening is effectively required — OFAC liability attaches to the operator (you), not the agent, and strict liability means intent does not matter.

The legal shape

OFAC enforcement is strict liability: a US person is responsible for transactions with sanctioned parties, whether executed by a human or an agent. An agent that pays a sanctioned wallet is your violation.

What the rails do

x402, AP2, ACP, and AgentKit move money — none of them screen recipients. The screen is a separate layer, and it is legally yours.

The practical answer

If your agent only reads data, screening may not apply. If it can pay, screen every destination before signing — one call, under 100 ms.