OFAC compliance for agent developers

Agent developers building payment-capable agents must include sanctions screening from day one. It is infrastructure, not a feature.

TL;DR

TL;DR: If your agent can pay, it must screen the counterparty before paying. Sanctions screening is core infrastructure for agent developers, not an optional add-on.

Why agents are exposed

An agent that spends money is a payment actor. When it pays a designated wallet, the developer is responsible. OFAC applies strict liability, so intent is not required. Protocols like x402, AP2, ACP, and Coinbase AgentKit move money but do not screen, which leaves the check to you.

Build it in from day one

• Screen: check wallet and name against the SDN List.
• Score: attach a risk score to the counterparty.
• Stop: block the payment on any match.
• Stamp: log the decision for audit.

Practical integration

Add one HTTP call before every payment, returning in under 100 ms. Integrate with the tools your agents already use, such as MCP, LangChain, CrewAI, or the OpenAI Agents SDK. Log every screen. A blocked match means the agent does not pay, and the transaction stops there.

Screening before spend, every time

The rule is simple: no screen, no spend. Before the agent signs any transaction, it checks the wallet and the counterparty name, and it only proceeds on a clean result. Because agents can spend at high volume with no human in the loop, a single unscreened path becomes many violations. Put the check at the front of every payment the agent can make.