If your AI agent paid a sanctioned counterparty, should you self-disclose? The rules, process, and potential penalty reductions.
If your AI agent processed a payment to a sanctioned counterparty, you should consider filing a Voluntary Self-Disclosure (VSD) with OFAC. A VSD can reduce the base penalty by up to 50% or more in some cases.
A Voluntary Self-Disclosure is a formal submission to OFAC describing an apparent violation that you discovered and are voluntarily reporting. OFAC considers VSDs as a significant mitigating factor in penalty calculations.
The disclosure must be made within a reasonable time after discovering the violation, describe the transaction in detail, identify all parties involved, explain the root cause, and describe remedial measures taken. For agent violations, include the agent logs, screening process (or lack thereof), and corrective actions.
Start by preserving every record. Agent logs, payment records, screening results, and configuration files all matter. Having a documented screening process that failed for a specific reason is far better than having no records at all. agentmail's audit dashboard provides the timestamps and results OFAC expects.
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