OFAC screening for charitable organizations

Charities operating in sanctioned regions face extra scrutiny, and humanitarian exemptions exist but require careful, documented compliance.

TL;DR

TL;DR: Charities operating in sanctioned regions face special OFAC scrutiny. Humanitarian exemptions exist, but they require careful compliance and a specific license in many cases.

Why charities are not exempt

Nonprofit status does not remove a charity from OFAC's reach. A charity that sends funds, goods, or crypto into a sanctioned region, or to a party on the Specially Designated Nationals and Blocked Persons List, has engaged in a prohibited transaction. Strict liability applies, so intent is not required, and penalties start at $356,000 per violation. Donor goodwill is not a defense.

How humanitarian exemptions work

OFAC does provide general and specific licenses for certain humanitarian activity, such as food and medicine, but the terms are narrow and must be met exactly. When the activity falls outside a general license, the charity must apply through OFAC's online portal and wait for a specific license, which can take weeks to months.

Practical compliance steps

• Screen every recipient wallet and organization before funds are released.
• Confirm whether a general license covers the activity, and document it.
• Use a screening API like sanctionsai.dev to check counterparties in under 100 ms.

Compassion and compliance must run together; screen the recipient first.

A documented license or general-license analysis should be saved next to the screening record, so the charity can show both the permission and the check.