By · · last updated 2026-08-08
A data-driven read of the OFAC enforcement record: settlement sizes, the screening gap, the crypto cases, and what the pattern means for agents.
The enforcement record is the best dataset on what screening gaps cost. Read across the cases, three patterns dominate.
Binance ($968M OFAC portion), Standard Chartered ($132M), Societe Generale ($53.9M) - each settlement scales with transaction volume. Thousands of small violations compound into hundreds of millions. An agent executing hundreds of payments is the same shape at machine speed.
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Kraken, Bittrex, Poloniex, Bitfinex, BitPay, Ripple, EtherDelta - every case traces to screening that did not run before settlement. Not exotic fraud: a missing pre-transaction check.
Mixers (Tornado Cash, Blender, Sinbad), exchanges (Garantex), DeFi (EtherDelta) - new rails, same obligation. The asset class does not change the prohibition.
The enforcement data is the argument for the screen: one call, sub-100 ms, before every payment. The enforcement dataset tracks the record.
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