Agent employs a sanctioned developer via crypto payment

What happens when an agent pays a developer on the SDN List, the strict-liability and 50 Percent Rule risk, and the control.

TL;DR

TL;DR: Paying a developer who is on the SDN List is a transaction with a blocked person under strict liability. Verify the counterparty with know-your-counterparty checks and BLOCK flagged matches before paying.

What happens

An agent is configured to hire contractors and settles the work in cryptocurrency. If the developer is on the SDN List, or works for an entity 50% or more owned by a blocked person, the payment violates sanctions even though the work itself is legitimate. Employment does not create an exception to a block, and the operator, not the agent, carries the exposure for the hire.

The risk

OFAC enforces under strict liability, so intent is not required, and civil penalties start at $356,000 per violation. The 50 Percent Rule blocks entities 50% or more owned by a blocked person, which means checking only the developer's name is not enough; ownership and employment ties must be reviewed too.

The control

Run know-your-counterparty checks before the first payment. agentmail's kya_verify attaches counterparty evidence to the hire, and sanctions_check screens the name against the SDN List of 19,218 names and the wallet against 947 OFAC-listed crypto wallets in one call under 100 ms. Clean returns ALLOW, flagged returns BLOCK, and the SCREEN, SCORE, STOP, STAMP protocol halts a flagged hire at the STOP gate with a documented record.