If we run an ofac check on an auto loan customer at application and don't have a hit, are we required to verify that customer against the OFAC list every time we are notified of an update? I don't see the point, there is nothing that can be blocked in this case.

Most banks run thier entire CIF data base against the list everytime it is updated. How do and why would you plan on extracting certain account types from such a scrub?

These particular loans are on a separate database.

Then you should address/justify it in your risk assessment if you are going to exclude them from your scrub.