You are never required to do an OFAC check; comparing names to the OFAC list is always a risk based decision.
If an individual, directly or indirectly, owns 50% or more of the legal entity customer opening the account, a hit on the individual is a hit on the legal entity customer. On any lesser percentage, checking the OFAC list is an obvious waste of time...
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.