Glossary
Facilitation (Sanctions)
Assisting a sanctioned party in a prohibited transaction, which can itself be a sanctions violation even without direct dealing.
Definition
Facilitation occurs when a person assists, supports, or enables a transaction by a sanctioned party that the sanctioned party could not perform themselves. Under OFAC's broad interpretation, the facilitator can be exposed to the same liability as if they had dealt with the sanctioned party directly.
Regulatory context
Facilitation is not a separate statute but an interpretive principle: providing services that enable a sanctioned party to access the US financial system or otherwise do what sanctions prohibit can constitute a violation by the facilitator.
Who it affects
Banks, agents, platforms, and intermediaries — especially those whose service is moving or holding funds. The risk is highest when the intermediary knows (or should know) that a counterparty is sanctioned.
Relevance to AI agents
An agent that routes funds, holds value, or executes transactions on behalf of a sanctioned counterparty is in facilitation territory. The agent must screen not only the immediate counterparty but understand on whose behalf it is acting.
SanctionsAI coverage
SanctionsAI screens the immediate counterparty. Facilitation analysis — understanding the ultimate beneficiary — requires the agent's operator to know their customer, not just the immediate address.
FAQ
1. Can I be liable for helping a sanctioned person do something they are barred from?
Yes, under OFAC's facilitation principle. Assisting a sanctioned party in a prohibited transaction can expose the facilitator to liability.
2. Does facilitation require intent?
Knowledge is an aggravating factor, but the analysis is fact-specific. The safest posture is to screen counterparties and decline to act where a sanctions match is present.
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