Should you run an OFAC on a POA and a co-trustee?

OFAC is a risk based process. Your OFAC risk assessment should address all endpoints at which transactions may occur through your bank and all parties may be involved in those transactions. The bank then determines the level of risk the bank wants to accept.

Or, I could just say yes or no, take your pick if that makes you feel any better. There are no right or wrong answers.

An OFAC check is conducted on anyone or any entity added to our core system. We found fewer "misses" when our policy is more encompassing. No thinking required.

Same here, we run OFAC on consumer or business being added to our core system.

Ditto.

Okay, thank you all for the replies.