OFAC screening for treasury management

How treasury teams screen outbound payments so corporate funds never reach a blocked party.

TL;DR

TL;DR: Treasury teams should screen every outbound payment against the SDN List before it is released. The 50 Percent Rule extends blocks to entities 50 percent or more owned by a blocked person, so ownership checks belong in the process.

The treasury is the last gate

A corporate treasury is where outbound money actually leaves the organization, which makes it the final and most important compliance gate. OFAC (the Office of Foreign Assets Control) is a strict liability regime: a treasury that wires or pays a blocked party violates sanctions even without intent, with civil penalties starting at $356,000 per violation.

Beyond the vendor name

The subtle risk in treasury is ownership. The 50 Percent Rule blocks any entity 50 percent or more owned by a blocked person, so a vendor whose name looks clean can still be a violation through its owners. Treasury screening should resolve the entity and its beneficial owners, not just match the name on the invoice.

Putting the check before release

agentmail, the screening API at sanctionsai.dev, fits into the payment approval step: one HTTP call under 100 ms returns clean (ALLOW) or flagged (BLOCK), checking 19,218 SDN names and 947 OFAC-listed crypto wallets across 16 jurisdictions, synced hourly. A flagged counterparty is stopped before the payment is released, which is the point where a treasury has full control.