OFAC sanctions: Complete overview

OFAC sanctions combine a legal framework, country and list-based programs, compliance obligations, and enforcement.

TL;DR

TL;DR: OFAC, the Office of Foreign Assets Control at the US Treasury, administers sanctions programs and enforces them under strict liability, with civil penalties starting at $356,000 per violation.

The legal framework

OFAC is the office within the US Treasury that administers and enforces economic sanctions. The core instrument is the SDN list, the Specially Designated Nationals and Blocked Persons list, which currently holds 19,218 names. Sanctions programs target countries, terrorism, narcotics, cyber activity, human rights, and non-proliferation, each with its own legal authority.

Compliance obligations

Compliance means checking that a counterparty is not on the list before doing business. Because OFAC applies strict liability, intent is not required, and the 50 Percent Rule extends blocking to entities owned 50% or more by a blocked person. For payment products this obligation lands at the moment funds move.

Enforcement

Enforcement follows a detection, investigation, penalty, and resolution path, with civil penalties starting at $356,000 per violation. The practical control is automated screening: one HTTP call, under 100 ms, returning ALLOW or BLOCK before any transfer. That single step is the difference between a clean flow and an enforcement action.

Where to start

If you are new to OFAC, start with the SDN list and one screening call before each payment. The free tier of a screening API is enough to test the flow, and the decision, ALLOW or BLOCK in under 100 ms, is the whole compliance loop in miniature. Everything else, programs, policies, and audits, builds on that single primitive.