Our usual and best advice in such circumstances is to challenge the source. A respectful version of "where is it written that ...?" will get you either a citation for this "requirement" or the knowledge that the source can't back it up. Try something like, "I'd like to learn more about that requirement. Can you tell me where to find it in OFAC's regulations or the law?"
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8