OFAC Risk Assessment Glossary Part 1

What a sanctions risk assessment is, and how scoring a counterparty works before payment.

TL;DR

TL;DR: A risk assessment is the process of evaluating how likely a counterparty is to be sanctioned or high risk. In the sanctionsai.dev flow, this is the risk_score step after screening.

What a risk assessment is

A sanctions risk assessment evaluates a counterparty against known sanctions data to estimate exposure. It goes beyond a binary match by producing a score or rating that reflects the counterparty's overall risk, drawing on lists such as the SDN List maintained by OFAC, the Office of Foreign Assets Control.

Why risk assessment matters

A binary ALLOW or BLOCK decision is useful, but a score helps an agent decide how to treat a borderline counterparty. Under strict liability, intent is not required for a violation, and penalties start at $356,000 per violation, so quantifying risk before payment is a meaningful control.

Risk assessment in practice

The sanctionsai.dev API follows the 4-Gate Agent Payment Protocol: SCREEN, then SCORE, then STOP a flagged payment, then STAMP the decision. Its tools include sanctions_check, risk_score, kya_verify, and dispute_open. Payment rails such as x402, AP2, ACP, and Coinbase AgentKit move money but do not score or screen. Not documented: the numeric scale or thresholds the score uses.