Strict Liability

The legal principle that a sanctions violation occurs regardless of intent or knowledge. You are liable even if you didn't know.

TL;DR

TL;DR: Strict liability means OFAC can penalize a sanctions violation even if the organization did not intend to break the rules or know it was dealing with a sanctioned party. Civil penalties start at $356,000 per violation.

What strict liability means

Under most legal standards, fault requires intent or at least negligence. Sanctions law is different. OFAC's position is that a person who deals with a blocked party is liable for the violation regardless of whether they knew, intended, or even had reason to suspect the counterparty was listed. Ignorance of the list, or of a counterparty's status, is not a defense.

Why it changes behavior

Because intent is irrelevant, the only reliable protection is prevention: do not transact with a listed party in the first place. That is what screening is for. A check before payment means the violation never occurs, which is far better than having to argue good faith after the fact.

How screening addresses it

An automated check compares the counterparty against the SDN List before funds move. If the check is clean, the payment proceeds. If it flags, the payment stops. Because the check is mechanical and runs on every transaction, it removes the reliance on human knowledge that strict liability punishes. tools such as sanctionsai.dev perform this in one HTTP call in under 100 ms, screening 19,218 SDN names and 947 OFAC-listed crypto wallets, so the check is practical on every payment rather than a sample.