I came from a larger bank that performed OFAC checks on all parties to a wire. We did not conduct wires for non-customers so we mainly conducted the checks for beneficiaries and beneficiary banks on outgoing wires and originator and originating banks on incoming wires.
I now work for a smaller bank who only conducts checks on beneficiaries and beneficiary banks (when they have time) on outgoing wires. We also do not conduct wire transfers for non-customers. The Compliance Manager for the bank said that the SENDING bank is responsible for OFAC compiance on their end and therefore, that is why we do not check the incoming wires.
Am I not correct that we should be checking this in case of transactions that need to be accepted and then blocked or rejected altogether.