OFAC Audit Trail Glossary Part 1

What an audit trail is in sanctions screening, and why recording decisions matters.

TL;DR

TL;DR: An audit trail is a record of screening decisions: who was screened, the result, and when. It documents good faith and supports any review or dispute after the fact.

What an audit trail is

An audit trail is a durable record of compliance decisions. For sanctions screening it captures which counterparty was checked, the result (ALLOW or BLOCK), and the timestamp, so the decision can be reconstructed later by the business or by a regulator such as OFAC, the Office of Foreign Assets Control.

Why audit trails matter

Because enforcement is strict liability, intent is not required for a violation, but a clear record that screening was performed shows good faith and supports any voluntary disclosure. If a flag is disputed, the audit trail is the evidence for what the system decided and why.

Audit trails in the screening flow

The sanctionsai.dev API uses the 4-Gate Agent Payment Protocol: SCREEN, SCORE, STOP, and STAMP. STAMP is the record that the decision was made, giving each payment a durable trail. The toolset includes sanctions_check, risk_score, kya_verify, and dispute_open. Not documented: the retention period or export format for these records.