OFAC Enforcement FAQs
Answers to common questions about OFAC enforcement, strict liability, and the penalties an operator faces.
TL;DR
TL;DR: OFAC enforces sanctions under strict liability, with civil penalties starting at $356,000 per violation. Screening prevents the transaction that triggers enforcement.
How enforcement works
OFAC enforces sanctions against the SDN List through civil penalties. The standard is strict liability, so a violation exists even without knowledge or intent, and penalties start at $356,000 per violation. For an automated agent, this means the operator is exposed the moment a designated counterparty gets paid, regardless of what the model intended.
Common questions
- What is the 50 Percent Rule? Entities owned 50 percent or more by a blocked person are also blocked.
- How does screening reduce exposure? It blocks flagged counterparties before payment, so the violative transaction never happens.
- What recourse exists? On a match, block, preserve records, and escalate; paid SanctionsAI plans include a $10K legal-fee guarantee.