OFAC Startup Compliance Guide Part 1
How early-stage teams can add OFAC screening to their paying agents without a big compliance budget.
TL;DR
TL;DR: A startup can screen agent payments for free at five checks per day, with no signup or key. Clean counterparties ALLOW and flagged ones BLOCK, which avoids strict liability penalties starting at $356,000.
Why startups cannot skip screening
OFAC strict liability applies to every size of company: intent is not required, and civil penalties start at $356,000 per violation. A small team running one paying agent faces the same legal exposure as a large firm, so screening must be built in from the first payment.
Starting cheap
The screening API has a free tier of five checks per day with no signup and no key. When volume grows, the Dev plan is $19/mo for 10,000 checks and the Pro plan is $99/mo for 100,000 checks. The API is MIT-licensed and self-hostable, so a startup can also run it in house.
Practical setup
- Begin with the free tier before wiring up billing.
- Call sanctions_check before each agent payment.
- Move to a paid tier as the number of checks grows.