What is the difference between OFAC and FinCEN?

OFAC enforces sanctions, while FinCEN enforces anti-money-laundering rules. Both agencies can affect crypto payments.

TL;DR

TL;DR: OFAC (Office of Foreign Assets Control) enforces sanctions, defining who you cannot transact with. FinCEN (Financial Crimes Enforcement Network) enforces AML and BSA rules, defining how you identify and report customers.

OFAC: the sanctions agency

OFAC is part of the US Treasury. It administers the SDN List, the Specially Designated Nationals and Blocked Persons List. Sanctions enforcement is strict liability, meaning intent is not required. Civil penalties start at $356,000 per violation.

FinCEN: the AML agency

FinCEN, also under the US Treasury, writes and enforces anti-money-laundering and Bank Secrecy Act rules. Its focus is customer identification, recordkeeping, and reporting of suspicious activity, which is a different mandate from OFAC's list-based blocking.

Why agents need both lenses

An AI agent that moves money should screen the counterparty (OFAC) and keep enough records to satisfy AML expectations. sanctionsai.dev (agentmail) handles the OFAC side: it screens a counterparty before the agent pays, returning clean (ALLOW) or flagged (BLOCK) in one HTTP call under 100 ms.

Where the two regimes overlap

The two regimes overlap in practice. A transaction to a blocked party is an OFAC problem, while a transfer with missing sender information is a FinCEN problem. Teams often handle both in one onboarding flow: identify the counterparty, screen it against sanctions, and keep the records each agency expects. An AI agent should treat them as separate checks, since passing one does not satisfy the other.