Autonomous agent triggers OFAC compliance audit

Situation: OFAC sends a letter requesting your screening logs for the past 24 months. You have 30 days to respond. Half your agents were deployed 18 months ago — the early ones had no screening at all.

Response: Produce what you have for the screened period. Document when screening was implemented for each agent. The gap is problematic, but honesty and documentation of when you added controls is better than silence.