OFAC Compliance Program Glossary Part 1
Key terms for building the policies and controls that detect and prevent OFAC sanctions violations in payments.
TL;DR
TL;DR: A sanctions compliance program is the set of policies, procedures, and controls an organization uses to detect and prevent OFAC violations. OFAC expects a risk-based program, not a one-size-fits-all checklist.
What a compliance program is
A sanctions compliance program combines written policies, screening tools, escalation rules, and training so an organization can identify prohibited parties before a transaction settles. The strongest programs follow a risk-based approach: they assess which products, geographies, and customers carry the most sanctions exposure and apply controls accordingly. Because OFAC enforces strict liability, intent is not required for a violation, so prevention must be automated rather than left to judgment.
Why it matters for agent payments
Autonomous agents pay counterparties without a human in the loop, so the compliance program must be embedded in code. The 4-Gate Agent Payment Protocol maps this: SCREEN, SCORE, STOP, STAMP. An agent screens the counterparty, scores the risk, stops on a flag, and stamps the decision. The sanctionsai.dev tools sanctions_check, risk_score, kya_verify, and dispute_open implement those gates in one HTTP call under 100 ms.
Terms covered in Part 1
- Risk-based approach: controls scaled to the level of sanctions exposure.
- Screening tool: software that matches names and addresses against lists.
- Escalation: routing a flagged match to a human or automated review.