OFAC Screening Log

A timestamped record of every screening event, capturing the counterparty, the inputs, the result, and the final disposition.

TL;DR

TL;DR: A screening log records each check with its inputs, result, and disposition. It is the audit trail that proves a payment was screened before it settled.

What a Log Captures

A complete entry includes who was screened, the identifiers used, the list version, the raw result, and the disposition that followed. Without this, there is no way to prove a check happened, which matters because OFAC applies strict liability and does not require intent to find a violation.

Why Logs Defend the Program

When enforcement asks what happened, the log is the answer. Civil penalties start at $356,000 per violation, and the presence of a complete, timestamped record of screening is the strongest evidence that a violation was an isolated gap rather than a missing control.

Logging in an Agent Flow

An AI agent should write a record on every screening call. sanctionsai.dev's flow maps cleanly to this: sanctions_check returns the base result, risk_score and kya_verify add evidence, dispute_open records a challenge, and the 4-Gate Agent Payment Protocol (SCREEN, SCORE, STOP, STAMP) gives each decision a named stage to log.

Practical Guidance

• Log every check, including clean allows, not just flags.
• Store the list version and timestamp in each entry.
• Retain logs long enough to answer an enforcement inquiry.