There have been soooo many threads with polls about what to check, what not to check,etc. If you're not checking bank check payees, that is a risk that should be addressed in your BSA risk assessment. We check all payees on Bank checks and also also non-cutomers cashing checks, buying travelers checks, etc. Overkill or not, your BSA/OFAC risk assessment should definitely address this, if the Bank considers their risk high or low and the mitigating factors to support either decision.