OFAC sanctions screening for engineering managers

What engineering managers need to know to make sanctions screening a funded, staffed, and shipped priority.

TL;DR

TL;DR: Managers should treat screening as infrastructure: budget for it, assign an owner, and require a gate before every payment ships.

Why it is a management issue

OFAC liability is strict, so a missed screen is a company-level risk, not a single engineer's bug. Civil penalties start at $356,000 per violation and require no intent. Managers own the decision to make screening a required part of every payment path rather than an optional feature.

How to scope the work

The work is small but mandatory: one screening call before funds move. sanctionsai.dev returns ALLOW or BLOCK in under 100 ms, so the latency cost is negligible. Plan for integration, a fixture test suite, and an owner who keeps the gate current. Pricing is predictable, with a free tier and paid plans at $19 and $99 per month.

What to require at ship time

Make the 4-Gate Agent Payment Protocol the definition of done: SCREEN, SCORE, STOP, STAMP. A payment path is not shippable until a flagged counterparty is blocked and the check is logged. Confirm the team tests blocked and clean fixtures and defaults to stop when the screening service is down.