OFAC sanctions compliance monitoring

Monitoring a screening program means reviewing logs, testing the controls, watching alerts, and running periodic audits.

TL;DR

TL;DR: Compliance monitoring keeps a screening program honest: review decision logs, test the screening controls, track alerts, and audit on a schedule.

Log reviews

A screening program only protects you if it actually runs. The first monitoring task is to review the decision log, a record of every counterparty checked, the ALLOW or BLOCK result, and a timestamp. If the log shows gaps, such as payments that moved without a check, that gap is itself a compliance problem.

Testing and alerts

Testing is the second layer. Periodically submit known blocked names and wallets to confirm the tool flags them, and submit clean counterparties to confirm they are allowed. Alerts should surface any flagged transaction immediately, so a BLOCK result is reviewed rather than silently overridden. SanctionsAI exposes this as discrete tools, including sanctions_check and risk_score, which makes each step observable.

Periodic audits

Finally, run a periodic audit of the whole program and confirm the data source is current. The SDN list syncs hourly in a live API and now holds 19,218 names, so a stale list is a real risk. Document each audit so you can show a regulator that monitoring was performed.

Building the cadence

A workable cadence combines daily log review with less frequent full audits. Review the decision log every day for skipped checks, test the tool weekly with known blocked and clean inputs, and audit the whole program quarterly. Document each activity so the monitoring effort itself is verifiable.