A three-agent sanctions-interdiction fleet that re-screens an entire counterparty book every time OFAC publishes — unattended, and graded against sources we do not control.
Amara runs grants at a humanitarian NGO moving money toward three sanctioned regions. The same strict-liability statute binds her and JPMorgan: intent is irrelevant, headcount is irrelevant. The morning Treasury updates the SDN list, every queued disbursement — grantees, field partners, vendors — becomes her personal federal exposure.
A true hit must be held and reported within 10 business days. A delisting means blocked funds must be released. Today she does it by hand, late, or not at all.
101 counterparties screened against all 19,199 records of the 08/07/2026 OFAC publication. 59 held, $1,181,434.51 frozen, 0 quarantined, 0 guard disagreements — and not one of those verdicts decided by a human.
Screening the seeded book verbatim scores 1.000 and means nothing — those names were copied out of the very publication being searched. So the reported number screens 400 deterministic perturbations: transliterations from OFAC's own alias lists, reordering, dropped particles, confusables. Seeded from SHA-256, so the set is byte-identical on your machine.
| population | expected | correct | reached the model |
|---|---|---|---|
| sentinelon the list, exact names | HOLD | 30 / 30 | 30 |
| variantsame person, different transliteration | HOLD | 29 / 30 | 29 |
| lookalikedifferent person, shared surname, contradicting DOB | CLEAR | 25 / 25 | 0 |
| ordinaryunrelated grantees | CLEAR | 16 / 16 | 0 |
The book is 400 names that were on the SDN list at seal time, chosen by the SHA-256 of each entry's uid — no RNG, byte-for-byte reproducible. It and its hash were committed on 2026-08-13, before any later OFAC publication existed. If Treasury delists one of them, git log proves the book predates the removal. As of 08/20, none has.