OFAC Fintech Compliance Guide Part 1
OFAC screening obligations for fintech products that let AI agents move or manage money.
TL;DR
TL;DR: Fintech platforms that let agents pay must screen each counterparty against the SDN List before the transfer. Clean parties ALLOW and flagged parties BLOCK; skipping the check risks penalties starting at $356,000.
Why fintech is exposed
A fintech product that moves money inherits OFAC obligations. Enforcement is strict liability: intent is not required, and civil penalties start at $356,000 per violation. If an agent can pay on behalf of a user, the platform must ensure that payment does not reach a listed party.
Building screening into the product
The screening API returns a decision in under 100 ms, drawing on 947 OFAC-listed crypto wallets and 19,218 SDN names across 16 jurisdictions, synced hourly. Integrations exist for x402, MCP, and Base/USDC, so the check can run inside the payment flow.
Practical steps
- Call sanctions_check before every agent-initiated transfer.
- STAMP clean payments for audit.
- Use risk_score for counterparties that need review.