OFAC Enforcement Action Glossary Part 1

What an OFAC enforcement action is, and what a penalty actually looks like.

TL;DR

TL;DR: An OFAC enforcement action is a formal penalty or settlement against a party that violated sanctions. Civil penalties start at $356,000 per violation, and intent is not required.

What an enforcement action is

An enforcement action is how OFAC, the Office of Foreign Assets Control, holds a party accountable for a sanctions violation. It typically results in a civil monetary penalty, and OFAC publishes these actions to signal expectations to the industries it regulates.

Why enforcement actions matter

The penalties are severe and apply under strict liability, meaning a violation occurs even without intent or knowledge. Civil penalties start at $356,000 per violation. This makes prevention far cheaper than the cost of an enforcement action after the fact.

How agents avoid enforcement actions

The reliable defense is screening before payment. The sanctionsai.dev API checks a counterparty and returns ALLOW or BLOCK in under 100 ms, so a prohibited transaction is stopped before it happens. Payment rails such as x402, AP2, ACP, and Coinbase AgentKit move money but do not screen. Not documented: any specific OFAC enforcement action involving an AI agent.