Screening for comprehensively sanctioned countries

How screening handles counterparties subject to comprehensive, country-based OFAC restrictions.

TL;DR

TL;DR: Some jurisdictions are subject to comprehensive OFAC restrictions that go beyond the SDN List. Screening must consider both country-based restrictions and list matches, and a counterparty in one of these jurisdictions requires extra care.

Country programs vs. the SDN List

OFAC (the Office of Foreign Assets Control) enforces the SDN List, the Specially Designated Nationals and Blocked Persons List, alongside country-based sanctions programs. In a comprehensively sanctioned jurisdiction, the restrictions can apply broadly rather than only to named persons, so a screen that checks names alone can miss the exposure.

What this means for a payment

For a counterparty in such a jurisdiction, the safe pattern is to treat the location as a strong signal and combine it with a current list match. The 50 Percent Rule still applies on top: an entity 50 percent or more owned by a blocked person is blocked regardless of jurisdiction. The precise list of sanctioned countries is maintained by OFAC and is not reproduced here.

How agentmail covers jurisdiction

agentmail's live data spans 16 jurisdictions, synced hourly, and its tools separate the layers: sanctions_check handles the list match, while risk_score adds a finer signal that helps flag higher-risk jurisdictions. The call returns clean (ALLOW) or flagged (BLOCK) in under 100 ms, so a treasury or agent can hold a payment for review when the jurisdiction itself raises concern.