OFAC Compliance Guide for Startups

Most OFAC compliance guides are written for banks with compliance departments. This guide is for startups — small teams, limited resources, real risk. Here is what you actually need in your first year.

The minimum viable compliance program

1. Write a one-page compliance policy. Who is responsible, what screening tool you use, what happens on a match. That is it.
2. Add screening before every payment. One API call. Free tier covers 5 checks/day for testing. Dev plan ($19/mo) covers production.
3. Keep screening logs. The paid tier does this automatically. Your audit trail is your defense.
4. Train your team. A 15-minute session once a year. Document who attended.

What you do NOT need in year one

You do not need a dedicated compliance officer, an annual external audit, a custom rule engine, or an enterprise GRC platform. Startups over-invest in compliance infrastructure and under-invest in actually screening transactions. Screen every payment — the rest can wait.