OFAC Compliance Obligation

The compliance obligation is the full set of duties under US sanctions: screening, blocking, reporting, recordkeeping, and due diligence.

TL;DR

TL;DR: An OFAC compliance obligation is the set of legal duties under US sanctions, including screening, blocking, reporting, recordkeeping, and due diligence.

What the obligation covers

The duty goes beyond a single screen. You must screen counterparties against the SDN List, block any match, report the block, keep records, and exercise due diligence about who you are dealing with. The 50 Percent Rule widens this, since an entity 50 percent or more owned by a blocked person is blocked too, and must be caught the same way.

Why it matters for agent payments

OFAC applies strict liability: intent is not required, and civil penalties start at $356,000 per violation. An AI agent that pays a listed wallet creates the same exposure as a human teller who wires a listed bank, so the obligation follows the payment, not the payer. Automation does not remove the duty; it just changes who executes the check.

Meeting it in practice

Automation makes the obligation routine. SanctionsAI screens 19,218 SDN names and 947 OFAC-listed crypto wallets in one call under 100 ms, returning ALLOW or BLOCK before funds move. The tools sanctions_check, risk_score, kya_verify, and dispute_open cover the check, the review, and the record, closing the loop on each duty. The point of each duty is the same: make sure no payment moves to a blocked party, and be able to prove you checked. Automation covers the first half; documentation covers the second.