OFAC Treasury Compliance Guide Part 1
What OFAC, the Office of Foreign Assets Control inside the US Treasury, requires before an agent pays a counterparty.
TL;DR
TL;DR: OFAC is a US Treasury office that enforces sanctions through the SDN List. Before an agent pays anyone, screen the counterparty against that list; clean parties ALLOW and blocked persons BLOCK.
The role of the US Treasury
OFAC, the Office of Foreign Assets Control, sits inside the US Treasury and publishes the SDN List, the Specially Designated Nationals and Blocked Persons List. The screening API mirrors this source directly, loading 19,218 SDN names from the US Treasury sdn.csv file, synced hourly.
Strict liability applies
OFAC enforcement is strict liability: intent is not required. A payment to a listed party violates sanctions whether or not the sender knew. Civil penalties start at $356,000 per violation, so screening before payment is the practical control.
What to screen
- Counterparty names against the SDN List.
- Crypto wallets against 947 OFAC-listed addresses.
- Entity ownership under the 50 Percent Rule.