What is facilitation in OFAC sanctions?

Facilitation occurs when a US person (or entity) assists, supports, or enables a transaction that would be prohibited if performed directly by a sanctioned party. This includes indirect assistance — providing financial, technological, or logistical support that furthers a prohibited transaction.

Agent-specific facilitation risks

An AI agent that routes a payment through an un-screened intermediary, even unknowingly, can be found to have facilitated a sanctions violation. If your agent's payment path includes entities that in turn transact with sanctioned parties, facilitation liability may attach.

Defense: screen the whole path

Screen every counterparty in the payment chain — not just the immediate recipient. If your agent uses multiple exchanges, wallets, or DeFi protocols, each hop is a potential facilitation point.