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...
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.