OFAC & Sanctions Compliance Services
ComplyFactor helps U.S. Money Services Businesses, fintechs, payment companies, and remittance and digital-asset businesses assess their sanctions exposure, design or strengthen OFAC compliance controls, and remediate gaps a review or partner has identified.
Sanctions risk isn't the same for every business — a remittance company sending funds to a handful of corridors and a payments platform onboarding customers globally don't carry the same exposure, and their controls shouldn't look identical either.
U.S. Treasury — Office of Foreign Assets Control
OFAC administers and enforces U.S. economic and trade sanctions programs. ComplyFactor is an independent compliance advisor, not affiliated with OFAC or the U.S. Treasury.
How ComplyFactor Helps Manage OFAC and Sanctions Risk
Sanctions engagements can start from one of a few places: a business building its first sanctions compliance framework, one reviewing controls that haven't kept pace with its growth, or one working through a specific gap a bank partner or internal review flagged. ComplyFactor supports each of these — assessing exposure, designing or revising the policies and controls that address it, and helping put changes into practice. None of this amounts to a guarantee of regulatory approval or a promise that a program prevents every future issue; it's practical work aimed at building a defensible, risk-based program.
U.S. Treasury
Office of Foreign Assets Control — the federal authority administering and enforcing U.S. sanctions programs.
Who Must Comply With OFAC Sanctions Regulations?
U.S. Persons
U.S. citizens and permanent residents wherever located, entities organized under U.S. law and their foreign branches, and persons physically present in the United States must comply.
Certain Non-U.S. Exposure
Non-U.S. persons can be subject to specific OFAC prohibitions, including restrictions on causing a U.S. person to violate sanctions or engaging in sanctions-evasion activity.
Program-Specific Restrictions
Additional exposure can arise under particular sanctions programs. The analysis depends on the facts and the relevant program — not a blanket rule.
Whether a specific business has meaningful OFAC exposure is usually where a sanctions risk assessment starts.
Building an OFAC and Sanctions Compliance Program
OFAC does not prescribe a single sanctions compliance program suitable for every organization. Its Framework for OFAC Compliance Commitments strongly encourages a risk-based program and identifies five components it considers essential — not universal statutory requirements or fixed legal pillars:
Management Commitment
Senior-level support and ownership of the program.
Risk Assessment
Identifying where sanctions exposure actually sits.
Internal Controls
Policies and procedures that put the risk assessment into practice.
Testing & Auditing
Checking whether the program actually works as designed.
Training
Making sure relevant staff understand their role in it.
What each component actually needs to say depends on the organization's size, products and services, customers and counterparties, geographic exposure, business model, and sanctions risk — components identified in OFAC's Framework, not a fixed template.
OFAC and Sanctions Risk Assessment
A sanctions risk assessment maps where exposure could actually arise. The point isn't to produce a document that restates OFAC's own guidance — it's to translate these risk factors into the specific controls a business needs.
Customers / Ownership
Who your customers are and their ownership structures.
Counterparties
Who else touches the transaction chain.
Products & Services
What's actually being offered.
Payment Flows
Transaction types and how funds move.
Geographic Exposure
Where the business and its customers operate.
Intermediaries / Agents
Any other parties in the chain.
This is where ComplyFactor's work on this typically sits: running the assessment, then building the screening, escalation, and policy framework the findings actually call for.
OFAC & Sanctions Controls We Can Help Build or Strengthen
Not every engagement includes every item below — scope is set during onboarding around the exposure the risk assessment actually identifies.
Expected Activity
Program Design
Written Policies & Procedures
Screening Framework Review/Design
Escalation & Investigation Procedures
Blocked/Rejected Transaction Review
Where relevant.
Ownership & Exposure Considerations
Including 50 Percent Rule analysis, where relevant.
Recordkeeping & Reporting Support
Training Framework
Internal-Control Review
Testing & Readiness Support
Gap Assessment & Remediation Roadmap
Implementation Support
Where agreed.
Sanctions Screening, Escalation and Internal Controls
Screening is one control among several, not the entire program. A potential name match is not automatically a sanctions violation — it should be reviewed against relevant identifiers, ownership information, and the applicable sanctions restrictions before a decision is made.
Potential Match
Flagged by the process
Review
Against identifiers & restrictions
Escalation
Where it can't be ruled out
Decision
By someone with authority
Action Where Applicable
Blocked, rejected, or reported
Recordkeeping
Decision and reasoning retained
Strengthening an Existing Sanctions Compliance Program
A program that worked at launch doesn't necessarily hold up as a business changes. Triggers include:
Any one of these is a reasonable prompt to revisit whether the existing controls still match the actual risk.
OFAC Compliance Gap Assessment and Remediation
A gap assessment reviews existing controls against the business's actual sanctions exposure, identifies where they've fallen short, and assesses the risk each gap represents before prioritizing what gets fixed first.
Existing Controls
Where things stand today
Gap Review
Against actual exposure
Risk Prioritization
Ranked, not treated equally
Remediation Plan
Revised controls, sequenced
Implementation Support
Where agreed
This is advisory work. It is not an OFAC examination, a regulatory certification, or a guarantee that a violation won't occur in the future.
Our OFAC & Sanctions Compliance Process
Useful gaps to test for include:
Business & Sanctions-Exposure Review
Understanding the business behind the risk.
Risk Assessment
Mapping where exposure actually sits.
Existing Control & Policy Review
Where controls already exist.
Program & Control Design or Enhancement
Building or revising what's needed.
Remediation & Implementation Planning
Sequencing the fixes by risk.
Implementation Support & Handover
Where agreed as part of the engagement.
Sanctions Compliance Deliverables
Deliverables depend on the agreed scope — a full program build and a targeted screening-control review don't produce the same set of documents.
OFAC Compliance vs BSA/AML Compliance
Identity Verification
Understanding Customer Risk
The two overlap operationally — a transaction that raises a sanctions concern often runs through the same monitoring system that flags money-laundering risk. Depending on its activities and exposure, a business may need both, and the controls should be coordinated rather than built in isolation.
Why Work With ComplyFactor for OFAC & Sanctions Compliance
U.S. MSB, Fintech & Payments Focus
Not a generalist sanctions practice.
Risk-Based Scoping
Tied to your actual exposure, not a standard checklist.
Products & Services
Aligned with the broader compliance work most MSBs also need.
Design & Remediation Together
Coordinated within the agreed engagement scope.
Clear Agreed Deliverables
Set before the engagement starts.
FAQs
U.S. persons — U.S. citizens and permanent residents wherever located, entities organized under U.S. law and their foreign branches, and persons physically present in the United States — must comply. Non-U.S. persons can also be subject to specific OFAC prohibitions, such as causing a U.S. person to violate sanctions or engaging in sanctions-evasion activity, and additional exposure can arise under particular sanctions programs — the analysis depends on the facts and the relevant program.
OFAC doesn't prescribe a single program suitable for every organization, but it expects businesses to comply with its sanctions rules regardless, and it treats the absence of a reasonable, risk-based program as a factor that can work against a business in an enforcement matter. Whether — and what — a program should cover depends on the business's own sanctions exposure, which a risk assessment identifies.
No. OFAC's guidance describes the internal controls a program should have, including screening, but it doesn't mandate specific software or technology. What matters is that whatever process a business uses actually identifies and addresses potential matches consistently.
Yes — where appropriate, the engagement can be scoped to a specific control area rather than requiring a full sanctions-program rebuild.
ComplyFactor can support the review of ownership and control information where relevant to sanctions exposure and screening. This isn't legal advice, and not every engagement includes detailed ownership analysis — it's scoped based on what the risk assessment identifies.
Typically current sanctions policies and procedures (if any), an overview of the business model, the customer and counterparty profile, products and services, geographic exposure, the existing screening and escalation process, and any relevant findings or partner requests. The exact scoping request depends on what the engagement covers.
Yes — where appropriate, the engagement can focus on the specific findings, gaps, or control areas identified during partner due diligence or review, rather than a broader program assessment.
Discuss Your OFAC Compliance Needs With Our Team
Tell us about your sanctions risk, current program design, screening controls, or any gaps that need remediation — we support U.S. MSBs, fintechs, and payment businesses at any of those stages.
