OFAC Compliance Review

A compliance review is a periodic internal or external assessment of how well a sanctions program is working.

TL;DR

TL;DR: An OFAC compliance review is a periodic internal or external assessment of the effectiveness of a sanctions compliance program.

What a review checks

A compliance review steps back from day to day screening and asks whether the program works end to end. It looks at screening coverage, whether matches were blocked and reported correctly, whether records are complete, and whether the SDN data behind the screen is current. SanctionsAI syncs 19,218 SDN names and 947 OFAC-listed crypto wallets hourly to keep that data fresh.

Why it matters for agent payments

An agent can run thousands of payments a day, so a review that samples transactions and finds unscreened ones is a serious signal. Because OFAC applies strict liability and penalties start at $356,000 per violation, finding the gap in a review is far better than finding it in an enforcement action, and the review is the point where the gap gets named and fixed.

Closing the loop

Feed review findings into remediation, then re test. The screen should return ALLOW or BLOCK in under 100 ms every time, and the record should show it. Treat the review as a recurring control, not a one time event, so the program keeps improving instead of drifting. A regular cadence turns the review into a habit, catching drift before it becomes a finding. The more routine it is, the less it feels like a disruption.