OFAC Facilitation Glossary Part 1
Core terms for the indirect help that OFAC treats as a sanctions violation even without a direct transaction.
TL;DR
TL;DR: Facilitation is helping another party complete a prohibited transaction, even indirectly. OFAC treats facilitation as a violation itself, so an agent that routes or enables a blocked payment can be liable.
What facilitation is
Facilitation occurs when a person or system helps another party engage in a transaction that sanctions prohibit, even if the facilitator never deals directly with the blocked party. Examples include routing funds, providing a platform, or processing a payment on behalf of a prohibited transaction. The key point is that the facilitator need not be the principal party; enabling the activity is enough to create liability under OFAC's strict liability standard.
Why it matters for agent payments
An AI agent that processes payments is a potential facilitator. If it forwards a transfer on behalf of a blocked party, or passes funds to a third party that will move them to a listed wallet, the agent can violate sanctions even though it never paid the blocked party directly. Screening each counterparty before the payment, clean equals ALLOW and flagged equals BLOCK, is the control that keeps an agent from becoming an unwitting facilitator. The sanctionsai.dev API performs that screen in one HTTP call under 100 ms.
Terms covered in Part 1
- Facilitation: indirect help that enables a prohibited transaction.
- Principal party: the party directly engaged in the transaction.
- Indirect provision: supplying a benefit that reaches a blocked party.