We are having an internal debate on how to run OFAC checks on business accounts. We run the business name and the names of the principals. However, is running the principals required? The business is the customer. Also on LLCs, must you run the members?
Appreciate any input.

Our OFAC checks for businesses are on the name of the entity, not the principals. The business is the customer, not the signers.

OFAC compliance is risk based; there is no circumstance where your bank is required to check the list.

OFAC guidance indicates that if the SDN owns more than half of the entity then the entity is also to be treated as an SDN. Checking the signatories and principals simply indicates your level of risk aversion.