I agree with RockChucker that running OFAC on a US financial institution wouldn't typically be a high priority. That said, I have seen auditors (and examiners) make these types of recommendations. The bottom line to me is that OFAC is risk-based, so whatever you do needs to be justified by risk (i.e. risk assessment) and then outlined in your procedures. If both of these things align with a decision to not review OFAC on your correspondent bank daily, I would agree that it isn't necessary.
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Adam Witmer, CRCM
All statements are my opinion, not those of my employer, and should not be taken as legal advice.
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