Are you sure that they are part of an OFAC requirement or Patriot Act?
But if it is OFAC it could be part of
OFAC Compliance Program
While not required by specific regulation, but as a matter of sound banking practice and in order to ensure compliance, banks should establish and maintain an effective, written OFAC compliance program commensurate with their OFAC risk profile (based on products, services, customers, and geographic locations). The program should identify higher-risk areas, provide for appropriate internal controls for screening and reporting, establish independent testing for compliance, designate a bank employee or employees as responsible for OFAC compliance, and create training programs for appropriate personnel in all relevant areas of the bank. A bank’s OFAC compliance program should be commensurate with its respective OFAC risk profile. http://www.ffiec.gov/bsa_aml_infobase/pages_manual/olm_037.htm