OFAC Screening Coverage Analysis

Measuring what percentage of transactions actually pass through a sanctions check and finding the gaps where payments skip screening entirely.

TL;DR

TL;DR: Coverage analysis measures how much of your payment volume is actually screened. The goal is to find the paths where transactions bypass the check, because those are the paths where OFAC risk concentrates.

Why coverage gaps appear

Coverage gaps usually come from architecture, not intent. A screening call may exist for one integration but not another, a batch job may skip a new wallet type, or a code path added later may not include the check. Coverage analysis audits each payment route to confirm a screening result is produced before funds move, and flags any route that does not.

Why it matters for agent payments

An agent stack often has many ways to spend: x402 calls, onchain transfers, and tool invocations from different frameworks. If screening is only wired into one of them, the rest move money unscreened. Coverage analysis makes the unscreened routes visible so screening can be added to every path an agent can use to pay.

Coverage questions to ask

• Does every payment route call screening before settling?
• Are new integrations added with the check already in place?
• Which counterparty types, such as wallets, are missing from the check?

How to run a coverage analysis

A coverage analysis starts by listing every path that can move money, then confirming a screening call sits on each one. For each route, the analyst checks whether the call is synchronous, whether it uses current data, and whether its result actually gates the payment. Routes that fail any of those checks are gaps. The output is a coverage percentage plus a list of gaps, and the gaps become the remediation queue.