OFAC compliance for open source projects

Open source maintainers still face sanctions obligations when they host payment or transfer features, so screening belongs in the project, not just in a company.

TL;DR

TL;DR: If your open source project moves or facilitates value transfer, add optional but easy screening hooks so downstream users can stay compliant without forking your code.

What maintainers should know

OFAC sanctions apply to transactions, and strict liability means intent is not required for a violation. An open source project that ships payment or wallet features can become part of someone's sanctions exposure, even if the maintainer never intended to process a blocked payment.

Contribution and dependency risks

Screen what your project touches. Review the provenance of contributions that handle funds, and be aware that a dependency that moves money, such as x402 or AP2, moves money but does not screen it. Add a screening step at the point where value is transferred.

A lightweight path

Because SanctionsAI is MIT-licensed and self-hostable, maintainers can wire in a screening call without a proprietary lock-in. Expose a small integration, for example through MCP, and document that clean means allow and flagged means block. This keeps the project open while making compliance easy for adopters.