I would hesitate to answer for OFAC. I commend you on what you are doing, though! Click on the launch pad, then on OFAC. All the way at the bottom of the page you'll see where you can contact OFAC, and the email that comes up goes right to Dennis Wood, the head of OFAC. He would be the one that would give you the positively correct answer. And it's quite a friendly contact. Go for it!