What is OFAC Strict Liability?

Strict liability means you are responsible for sanctions violations regardless of intent or knowledge. If your agent pays a sanctioned wallet, you are liable — even if you didn't know the wallet was sanctioned.

What this means for AI agents

There is no automation exemption. Deploying an agent that transacts without screening is operating without controls — an aggravating factor in penalty calculations.

How to protect yourself

Screen before every transaction. Document your compliance program. Maintain audit logs.

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