REFERENCE · §11 · LAST REVIEWED 2026-04-27

ACF §11 — Sanctions & Screening

Sanctions screening for agent-mediated transactions is the discipline of ensuring every regulated counterparty interaction the agent initiates or facilitates is screened against applicable sanctions lists in real time, with audit-grade evidence of the screening, the lists used, and the disposition of every alert.

OFAC, UK OFSI, EU consolidated, UN Security Council — sanctions list compliance is a strict-liability regime. An agent that initiates or facilitates a regulated counterparty interaction without real-time screening exposes the firm to civil and criminal liability. The framework section specifies: which lists, at what frequency, with what evidence, and what to do when an alert fires inside an agent-mediated session. Maps to BSA/AML rules, OFAC Recent Actions, FATF Recommendation 7, EU AML Directive 6.

Regulatory anchors

• OFAC 31 CFR Part 501
• UK OFSI
• EU AML Directive 6
• FATF Rec. 7
• MiCA Art. 96
• VARA Markets Conduct

What this covers

• Real-time vs. batch screening posture per agent interaction class
• Lists in scope and refresh cadence
• Alert-handling: hold, escalate, block, evidence
• Secondary-sanctions exposure assessment
• Documentation that survives an OFAC subpoena

Common gaps

• Batch screening only — agent-initiated interactions land before screening completes
• List refresh cadence not aligned with sanctions designation cycles
• Alert-handling runbook does not contemplate agent-mediated sessions
• Secondary-sanctions risk treated as "out of scope" without analysis

Related sections

• §8 — Third-Party Risk

  Outbound API calls made by the agent on behalf of the firm.

• §10 — Data Governance

  Training data, prompt caching, retention, and the regulator-facing posture for each.

• §3 — Audit Trail

  Every agent action logged with sufficient detail to reconstruct intent and outcome.

• §12 — Incident Response

  When the agent does the wrong thing — runbook, regulator notification, customer remediation.

Reference compiled by Sebastian Heine. Editorial perspective at The SHeine Brief.