Our bank uses our customer database to search for the OFAC and 314(a) lists. Therefore, I changed policy to prohibit the sale of any monetary instrument to non-customers. Branches are now balking because they have many non-customers coming in with large checks drawn on good customers (mostly lawyers) of the bank and the non-customers are wishing to cash a portion of the check and get a cashier's check for the remaining. Would the non-customer be considered the purchaser (therefore requiring us to check their names against the lists)? Or can we consider this an exchange and not have to check their names?