Scenario: OFAC Audit Request

How an OFAC information request plays out — and why the audit trail is the answer.

The setup

Your company receives an OFAC information request after a flagged transaction chain. You have 30 days (typical) to respond with records.

What OFAC wants

• Transaction records for the flagged period
• Evidence of screening controls in place
• Policies, logs, and decision trails

With an audit trail

Every screened transaction is logged: wallet, timestamp, match status, list version, decision. The response becomes a report, not a reconstruction project.

Without one

You are reconstructing months of agent activity from provider dashboards — and explaining why no screen ran. That is the difference between a documented process and a finding.