What is an OFAC compliance program?

An OFAC compliance program is a documented set of policies, procedures, and controls that an organization implements to prevent, detect, and respond to sanctions violations. OFAC's Enforcement Guidelines explicitly name it as the most important mitigating factor when calculating penalties.

Five pillars of a compliance program

1. Management commitment: Senior leadership has approved and supports the program.
2. Risk assessment: Your organization's specific sanctions risks are identified and documented.
3. Internal controls: Screening tools, policies, and procedures are in place and tested.
4. Testing and audit: The program is periodically tested for effectiveness.
5. Training: Relevant staff receive sanctions compliance training.

For AI agent operators

Your compliance program for autonomous agents should additionally cover: which agents have payment authority, what screening happens before every payment, how matches are handled, and audit log retention. Even a one-page document that covers these points is infinitely better than nothing.