Predictika · OFAC sanctions for banks

An AI payments agent's sanctions action, checked before it goes out

An AI payments agent at a community bank prepares a sanctions action on a payment: process it, block the funds and report, reject it and report, or release blocked funds. Before it goes out, the agent sends it to Predictika, which checks it against a declarative model of OFAC rules, including the 50 Percent Rule, blocked accounts, reporting deadlines and licenses, and returns a verdict, every reason and the figures it computed.

Scope: OFAC sanctions actions on bank payments and accounts — processing, blocking, rejecting and releasing funds, with the 50 Percent Rule, alert review, licenses, reporting and recordkeeping. See everything this validator covers

This validator checks what the screening result, the ownership, the alert history and the proposed action imply under OFAC rules, for a fictional community bank, Harborview. It does not match names and does not see the sanctions list: the bank's own screening tool supplies the match result. It works alongside that tool and the bank's ownership data.

  • Ownership — the owners of the customer entity, with the percent each holds and whether each is on the sanctions list. The validator adds up the listed percentages itself and compares the total with the figure the agent states. Listed owners at 50 percent or more block the payment (the OFAC 50 Percent Rule); 25 to 49 percent goes to compliance.
  • Screening and alerts — a direct match blocks processing; a possible match with an open alert goes to a compliance officer; a possible match whose alert was closed at first level only is blocked until it has second-level review; a customer left unscreened more than one day after a list update goes to approval (bank policy).
  • The action itself — block versus reject: funds are blocked when a blocked person has an interest and rejected when none does; blocked funds go in a segregated, interest-bearing blocked account; blocking and reject reports are due within 10 business days; records are kept for 10 years; a payment under a comprehensive sanctions program needs a license, and a license on file goes to the BSA officer to confirm.
  • Releasing blocked funds — only under a specific license from OFAC, confirmed by the BSA officer.
  • Approvals — compliance officer for ownership and alerts; BSA officer for anything that rests on a license. A BSA officer's approval covers a compliance officer's items too.

Any sanctions action on a payment or account that touches these rules is in scope — not only the scenarios pictured here. Not covered: name matching and fuzzy matching, cover-payment and wire-stripping checks, other sanctions regimes, penalty calculation and filing the reports themselves. The program tiers, the 25 percent watch level and the one day rescreen limit are illustrative bank policy; the citations come from public sources and have not been reviewed by a sanctions specialist. This is not legal advice.

The AI payments agentPrepares the sanctions action on a payment from the bank's screening result and says it is ready.
Predictika validatorChecks every rule at once and returns the verdict, each finding, and the computed figures.

8 scenarios in 4 groups · each group runs from the agent’s first attempt to the outcome · click one to switch

What the agent proposes

The AI payments agent says

Illustrative agent statement. The validator receives the structured request below.

Proposing agent: AI payments agent (scripted)

Before sending, the agent must call Recorded run

Predictika validator


      

        
        
        
      

      
Waiting for the call.

      
    

  

  
  

    
Where a name-screening tool alone gets it wrong
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Our assessment of what a name-screening or alert-management tool does with the same cases. It is a judgment about what such a tool is built for, not a claim that nothing can be built around it.

    
What the validator caughtName-screening tool alonePredictika
Listed owners that add up to 50 percent or moreNot what it is built for
A name screen compares one name with the list. Three owners at 30, 30 and 40 percent produce no hit on the entity, even when two of the owners are listed; the total comes only from ownership data and a calculation.		The owners are inputs; the validator adds up the listed percentages and blocks at 50 percent or more.
An alert closed at first levelOnly when someone is vigilant
The tool raises the alert; whether it is closed at first level or reviewed again is the bank's workflow, and a closed alert can go unnoticed.		The alert status is an input; a possible match closed at first level blocks the payment.
Block versus rejectNot what it is built for
Whether funds are blocked or rejected depends on whether a blocked person has an interest, which is a conclusion drawn from the screening result, the ownership and the program, not a field in the screening tool.		The validator derives whether a blocked person has an interest and blocks the wrong choice either way.
Blocked account, 10 business day report and 10 year recordNot what it is built for
These are properties of what the bank does after a hit, not of the screening itself.		The account, the report timing and the record period are inputs and are checked on every call.
A customer not rescreened after a list updateOnly with workarounds
Rescreening is scheduled in the tool or outside it; the gap between a list update and the next screening is not compared with a limit unless someone builds that check.		The days unscreened after the latest list update are an input and are compared with the bank's limit.
Releasing blocked fundsNot what it is built for
Release depends on a specific license and a named approver, which sit outside name screening.		The license and the approval on record are inputs; release without a specific license is blocked.
Every problem returned in one answerOnly with workarounds
Checks that run at different steps tend to surface one problem at a time, so the next one shows only after the first is fixed.		All findings come back together, whatever order the choices arrived in.

  

  

    
What this validator catches: findings from its test cases
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Every rule is checked on every call, in any order the choices arrive; one problem never hides another. Blocking findings stop the request; approval findings need a person to sign off; everything else is computed.

    
1Listed parties own 60 percent of this entity in total, at or above the 50 percent that makes the entity blocked too (OFAC 50 Percent Rule). The payment cannot be processed.
2Listed parties own 49 percent of this entity in total, below the 50 percent blocking line but above the bank 25 percent watch level. Compliance must review the ownership.
3Listed parties own 50 percent of this entity in total, at or above the 50 percent that makes the entity blocked too (OFAC 50 Percent Rule). The payment cannot be processed.
4The request states 20 percent listed ownership, but the owners provided add up to 60 percent.
5The customer is a direct match on the sanctions list, so the payment cannot be processed. The funds must be blocked and reported (31 CFR 501.603).
6A possible-match alert was closed at first level only. A possible match needs second-level review before the payment is processed.
7The customer is a possible match and the alert is still open. A compliance officer must clear or reject the match.
8The customer went 30 days unscreened after the latest list update, over the 1 day limit (bank policy). Rescreen before processing.
9Iran is under a comprehensive sanctions program and no license is on file. A prohibited payment is rejected and reported, not processed (31 CFR 501.604).
10No blocked person has an interest in this payment, so the funds are rejected, not blocked. Resubmit as reject and report.
11A blocked person has an interest in this payment, so the funds must be blocked, not rejected. Resubmit as block and report.
12Blocked funds must be held in a segregated, interest-bearing blocked account. The proposed account is not a blocked, interest-bearing account.
13The report is planned 14 business days out, past the 10 business day limit for blocking and reject reports (31 CFR 501.603 and 501.604).
14The record is kept for 5 years. OFAC recordkeeping is 10 years (31 CFR 501.601, as amended in 2,025).
15A license is on file for this payment involving Iran. The BSA officer must confirm that it covers this payment, parties and amount.
16Blocked funds can be released only under a specific license from OFAC. None is on file.
17A specific license is on file for releasing these funds. The BSA officer must confirm that it covers this release.

  

  

    
Scenarios and results
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The recorded result of the validator for each scenario on this page: the request the AI agent sent, the verdict, and every finding, in the order they appear above.

    
1. Calder Marine Supply wire: A wire for a Mexican exporter with three owners, two of them on the sanctions list

    
The agent's request. Please process the incoming wire for Calder Marine Supply, a Harborview customer in Mexico. The screening found no match. The owners hold 30, 30 and 40 percent, and the first and second owners are on the sanctions list. The listed ownership is 30 percent. The customer was rescreened on the day of the latest list update. It is ready to go.

    
Verdict: Blocked.

    
    
      
  • Listed owners hold 50 percent or more. Listed parties own 60 percent of this entity in total, at or above the 50 percent that makes the entity blocked too (OFAC 50 Percent Rule). The payment cannot be processed.
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  • Stated ownership differs from the owners. The request states 30 percent listed ownership, but the owners provided add up to 60 percent.
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2. Calder Marine Supply wire: The agent resubmits after fixing the errors

    
The agent's request. Please block the funds from the Calder Marine Supply wire, held in the general ledger, and file the blocking report in 14 business days. The record is kept for 10 years. The listed ownership is 60 percent. It is ready to go.

    
Verdict: Blocked.

    
    
      
  • Blocked funds not in a blocked, interest-bearing account. Blocked funds must be held in a segregated, interest-bearing blocked account. The proposed account is not a blocked, interest-bearing account.
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  • Report past the 10 business day limit. The report is planned 14 business days out, past the 10 business day limit for blocking and reject reports (31 CFR 501.603 and 501.604).
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3. Calder Marine Supply wire: The agent resubmits after fixing the errors

    
The agent's request. Please block the funds from the Calder Marine Supply wire, held in a blocked, interest-bearing account, and file the blocking report in 8 business days. The record is kept for 10 years. The listed ownership is 60 percent. It is ready to go.

    
Verdict: Allowed.

    
4. Bayline Imports wire to Iran: A wire to a supplier in Iran, with an open screening alert

    
The agent's request. Please process the incoming wire for Calder Marine Supply, a Harborview customer in Mexico, to a supplier in Iran. The screening found a possible match, and the alert is open. The sole owner holds 100 percent and is not on the sanctions list. The listed ownership is 0 percent. The customer was rescreened 3 days after the latest list update. It is ready to go.

    
Verdict: Blocked.

    
    
      
  • No license for a comprehensive program. Iran is under a comprehensive sanctions program and no license is on file. A prohibited payment is rejected and reported, not processed (31 CFR 501.604).
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  • Possible match with an open alert. The customer is a possible match and the alert is still open. A compliance officer must clear or reject the match.
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  • Customer not rescreened after a list update. The customer went 3 days unscreened after the latest list update, over the 1 day limit (bank policy). Rescreen before processing.
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5. Bayline Imports wire to Iran: The agent resubmits after fixing the errors

    
The agent's request. Please reject the wire for Calder Marine Supply and file the reject report in 4 business days. The record is kept for 10 years. The listed ownership is 0 percent. It is ready to go.

    
Verdict: Allowed.

    
6. Fairmont Dental Supply alert: A wire for a German dental supplier, with a screening alert closed at first level

    
The agent's request. Please process the incoming wire for Calder Marine Supply, a Harborview customer in Mexico. The screening found a possible match, and the alert is closed at first level. The sole owner holds 100 percent and is not on the sanctions list. The listed ownership is 0 percent. The customer was rescreened on the day of the latest list update. It is ready to go.

    
Verdict: Blocked.

    
    
      
  • Alert closed without second-level review. A possible-match alert was closed at first level only. A possible match needs second-level review before the payment is processed.
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7. Fairmont Dental Supply alert: The agent resubmits after fixing the errors

    
The agent's request. Please process the incoming wire for Calder Marine Supply, a Harborview customer in Mexico. The screening found a possible match, and the alert is cleared at second level. The sole owner holds 100 percent and is not on the sanctions list. The listed ownership is 0 percent. The customer was rescreened on the day of the latest list update. It is ready to go.

    
Verdict: Allowed.

    
8. Licensed wire to Iran: A wire to Iran for a relief fund that holds a specific license from OFAC

    
The agent's request. Please process the incoming wire for Calder Marine Supply, a Harborview customer in Mexico, to a supplier in Iran. The screening found no match. A specific license is on file. The sole owner holds 100 percent and is not on the sanctions list. The listed ownership is 0 percent. The customer was rescreened on the day of the latest list update. It is ready to go.

    
Verdict: Needs approval.

    
    
      
  • License to be confirmed by the BSA officer. A license is on file for this payment involving Iran. The BSA officer must confirm that it covers this payment, parties and amount.
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Narration transcript
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The text of the narrated walkthrough, step by step.

    
    
      
  1. Welcome to a demo of Predictika's Validator. An AI payments agent at a community bank prepares a sanctions action on a payment: process it, block the funds and report, reject it and report, and more. Before it goes out, the agent sends it to Predictika, which checks it against a declarative model of OFAC rules, including the 50 Percent Rule, blocked accounts, reporting deadlines and licenses, and returns a verdict, every reason and the figures it computed.
    2. 
      
  2. I will start with the first request by the agent.
    3. 
      
  3. The agent says. Please process the incoming wire for Calder Marine Supply, a Harborview customer in Mexico. The screening found no match. The rest of the request is on screen. The listed ownership is 30 percent.
    4. 
      
  4. Before it goes out, the agent calls the validator.
    5. 
      
  5. Blocked, with two findings, all in one answer. Listed parties own 60 percent of this entity in total, at or above the 50 percent that makes the entity blocked too (OFAC 50 Percent Rule). The payment cannot be processed. The request states 30 percent listed ownership, but the owners provided add up to 60 percent.
    6. 
      
  6. The validator returned two blocking findings in one answer, including: listed owners hold 50 percent or more; stated ownership differs from the owners. For example: Listed parties own 60 percent of this entity in total, at or above the 50 percent that makes the entity blocked too (OFAC 50 Percent Rule). The payment cannot be processed. A name screen alone would pass most of this; it shows only when the owners, the alert, the action, the account and the reporting are checked against each other.
    7. 
      
  7. What this shows: for listed owners that add up to 50 percent or more, a name-screening tool alone is not built for this.
    8. 
      
  8. Now the agent resubmits.
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  9. The corrected request. It changes the action to block and report and the stated listed ownership to 60 percent. It sets the funds held in to the general ledger, the business days to report to 14 and the record kept to 10 years.
    10. 
      
  10. It calls the validator again.
    11. 
      
  11. Still blocked, with two findings, all in one answer. Blocked funds must be held in a segregated, interest-bearing blocked account. The proposed account is not a blocked, interest-bearing account. The report is planned 14 business days out, past the 10 business day limit for blocking and reject reports (31 CFR 501.603 and 501.604).
    12. 
      
  12. Two findings were cleared. The request is still blocked, now on two new findings: blocked funds not in a blocked, interest-bearing account and report past the 10 business day limit.
    13. 
      
  13. The agent resubmits once more.
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  14. The revised request. It changes the funds held in to a blocked, interest-bearing account and the business days to report to 8.
    15. 
      
  15. It calls the validator once more.
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  16. This time the validator clears it.
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  17. Both earlier findings are cleared, and the validator's listed ownership, 60 percent, matches the owners.
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  18. Two problems caught in one call, fixed in two passes, and a clean request. That is the value of Predictika's validator: catching mistakes before the action runs.
    19.