OFAC Autogen Compliance Guide Part 1
How OFAC screening applies to multi-agent systems built with Microsoft AutoGen, where several agents coordinate payments.
TL;DR
TL;DR: AutoGen lets multiple agents collaborate, including on payment tasks, but it does not screen counterparties. Insert a sanctions check before any agent pays so clean parties ALLOW and flagged parties BLOCK.
Why multi-agent systems need screening
In an AutoGen system, one agent may plan a task while another executes the transfer. That split does not reduce sanctions risk. OFAC is strict liability: intent is not required, and civil penalties start at $356,000 per violation. The payment step is where a listed party would slip through.
Where to place the check
Add sanctions_check to the agent that performs the payment, right before it transfers value. A single HTTP call returns a decision in under 100 ms, drawing on 947 OFAC-listed crypto wallets and 19,218 SDN names. The 4-Gate protocol, SCREEN, SCORE, STOP, STAMP, keeps the flow auditable.
Practical steps
- Gate the payment agent behind sanctions_check.
- STAMP clean payments for a durable audit log.
- Use risk_score to route borderline cases to review.