(shakes head).... I sure hope you run the National Credit Union Administration through OFAC every time you need to send a remittance to them.
It's one thing to have an automated system that screens all fields. It's quite another to require a MANUAL screen every time you need to send a wire to Bank of America. OFAC does NOT require that, and your OFAC program should be risked based.
But if that's how your NCUA examiner wants to play, then I would suggest that, before you allow them to plug in their laptop, get a cup of coffee, or anything else, you make them wait while you run NCUA and the examiner's name through your OFAC screen.
Yes - I am being snarky but I hate when common sense goes out the window.
Regulations are a poor substitute for ethics.