OFAC Iran Sanctions Screening

Screening under the comprehensive Iran sanctions program, with broad prohibitions and limited exceptions for humanitarian trade and information services.

TL;DR

TL;DR: Iran is comprehensively sanctioned, so most transactions are prohibited, with narrow exceptions for humanitarian trade and information services. Screening must catch both Iranian counterparties and prohibited transaction types.

What the program restricts

Iran sanctions impose broad prohibitions that cover most trade and financial activity, while carving out limited exceptions for humanitarian goods and the free flow of information. A payment can be a violation either because of who the counterparty is or because of what the transaction funds. Screening therefore has to consider identity, jurisdiction, and the nature of the payment together.

Why it matters for agent payments

An AI agent routing a cross-border payment cannot rely on a name match alone, because the program targets a jurisdiction as a whole. A screening call that includes the counterparty's country alongside the name and wallet gives the agent the signal to BLOCK before funds move. With strict liability in effect, the operator is responsible even when the agent made the transfer on its own.

What to check before paying

• Counterparty identity and wallet
• Jurisdiction associated with the transaction
• Whether an exception or license covers the payment

The compliance reality

The compliance reality is that a transaction with an Iranian counterparty is presumptively prohibited unless a specific exception or license applies. The burden is on the operator to confirm the exception, not on OFAC to prove there is not one. For an agent, the practical rule is to BLOCK Iranian-jurisdiction payments by default and route any claimed exception to a human review, rather than letting the agent attempt to interpret the exception on its own.