Components of an OFAC compliance program
A working program needs screening, scoring, a stop rule, and a record, plus governance and training around them.
TL;DR
TL;DR: An OFAC compliance program has four operational gates (SCREEN, SCORE, STOP, STAMP) supported by policy, training, auditing, and a dispute path, each mapping to a concrete tool.
The four gates
The 4-Gate Agent Payment Protocol gives a clean operational skeleton. SCREEN the counterparty against the SDN List and listed wallets. SCORE the risk. STOP the transaction if flagged. STAMP the decision into a record. These four steps turn compliance from an abstract duty into a repeatable process.
Supporting components
- Policy: a written statement of when and how screening happens.
- Training: staff who understand what a match means and what to do.
- Auditing: periodic review of past decisions for consistency.
- Dispute handling: a path to challenge a false match.
Tools that map to components
Each component has a matching tool in the sanctionsai.dev API: sanctions_check implements SCREEN, risk_score implements SCORE, dispute_open implements the dispute path, and the STAMP step records the outcome. kya_verify documents the counterparty, feeding the audit trail that regulators and partners expect.