Sanctions Compliance Officer

The individual accountable for an organization's sanctions program, whether a dedicated role or an added responsibility.

TL;DR

TL;DR: A sanctions compliance officer owns the screening program and its outcomes. The role can be dedicated or folded into another position, but the accountability must be explicit.

What the Role Owns

The compliance officer is responsible for the program working end to end: that screening happens before payments, that flagged matches are reviewed and documented, that list data stays current, and that records exist for audit. In a small team this may be one person with several duties.

Why Accountability Matters

OFAC applies strict liability, and civil penalties start at $356,000 per violation. Without a named owner, screening decisions fall through the cracks and no one is positioned to fix a gap before it becomes an enforcement problem.

The Officer's Job With Agent Payments

When an AI agent pays counterparties, the compliance officer oversees the screening configuration. That means verifying the agent calls sanctions_check before paying, reviewing risk_score and kya_verify results on unclear cases, and keeping a log of every disposition through the 4-Gate Agent Payment Protocol (SCREEN, SCORE, STOP, STAMP).

Practical Guidance

• Name the owner in writing, even in a small team.
• Give the officer authority to pause payments, not just advise.
• Have the officer review the screening log on a regular cadence.