I am having a debate with my new account people. I am saying we should be doing a search on the organization or corporation and a search on the signers if they are not our customers already. The branches are saying they only need to search the organization or corporation name.
I read 31 CFR 500 to see if I could find a specific reference to who needs to be searched and I didn't see it. All I could find was the definition of person as an individual, partnership, association, corporation or other organization.

We check on signers/owners in addition to the organization.

Your Board approved KYC/CIP policy must address this issue, refer to it. FYI, we CIP signers but not all banks do.

Devsfan, I think anon is inquiring about OFAC verification not identification under CIP requirements.

We check everyone involved here. We now even check the payees of our monetary instruments over $3,000 per our independent auditor.

Pizzazz, You are correct, I mis-read the original post (must have CIP obsession).

LOL Devsfan, I hear you!