We are able to create a new CIF for someone even if they are not an owner on the account (or safe box) - as rlcarey mentioned above.
And as Ken_Pegasus mentioned, if you're OFAC checking a box owner why would you not OFAC check someone else authorized to enter the box?
To your question, SuperHeroCapReq, how are we documenting this OFAC check?
We have a new account checklist for all accounts with a box to check if we completed the OFAC check on all signers on the account we opened. We also print out the OFAC results of the person we checked. These results are scanned to the account number in a document imaging program we have. Then of course, our entire customer database is regularly scanned for OFAC hits & we check the 314(a) lists that come out.
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