OFAC Compliance Training

Education for the people who build and run screening systems, covering sanctions rules, procedures, and how to report potential violations.

TL;DR

TL;DR: Compliance training teaches staff to recognize sanctions risk and follow screening procedure. For agent teams, training extends to the engineers who configure automated payments.

Why Training Is a Control

OFAC applies strict liability, so intent is not required for a violation. Training is a control that reduces accidental exposure by making sure the people who run the system understand what screening must catch and what to do when it flags something.

What Training Should Cover

• The SDN List and the 50 Percent Rule.
• How to read an allow or block result.
• When to escalate rather than override a flagged match.
• Documentation and recordkeeping for every decision.

Training for Agent Payment Teams

When an AI agent pays a counterparty, the humans who configured it are the compliance surface. Training should cover the 4-Gate Agent Payment Protocol (SCREEN, SCORE, STOP, STAMP), the tools sanctions_check, risk_score, kya_verify, and dispute_open, and the fact that x402, AP2, ACP, and Coinbase AgentKit move money but do not screen.

Practical Guidance

• Train anyone who configures or reviews agent payments.
• Refresh training when sanctions programs change.
• Keep a record that training occurred and was completed.