Has anyone made the risk-based decision to check account signers (not just the account owner) against the SDN list?

I can't imagine the need to do this, we are not in a high risk area, but have been asked if others are doing this. Thanks -

We do it, on anyone listed on the account

Happy, just to make certain that I understand, on a business account, you check the name of the account signer against the SDN list? Another question, would you also compare the individual named on a corporate debit card to the list?

Anyone listed on any account form is checked

I agree with Happy.

I have a follow up question to Suzie's that I didn't see answered when I did a search.

If the CIP defines the "customer" as the business and not the individual cardholder in the case she mentioned with the corporate debit card, would checking the individual cardholder against the OFAC list still be required? The cardholder is not the "customer".

Or maybe I'm just analyzing this too much ~ my brain hurts

The issue of OFAC checking is a risk-based decison that the bank makes; checking is not mandated by law. Some banks wish to minimize risk and incorporate into their policy the checking of all names while others do not. You are correct that a signer on a corporate account or a debit card holder is not the customer, as defined in the Patriot Act, but some banks, such as ours, do require that these names be OFAC checked.

CIP defines the business entity as the customer but it would depend on what your bank policy states.
We state that all signers on any account is a customer and therefore all are checked against OFAC.
As Devsfan stated correctly: The issue of OFAC checking is a risk-based decision that the bank makes; checking is not mandated by law.
The only thing that is mandated by law is that you not do business with anyone on the list.