How far do we need to go with AML/KYC/OFAC screening in the following situations?

1) Purchasing a participation from a CDFI that made a construction loan to a nonprofit developers
- Do we need to treat the end borrower as our customer and screen accordingly? I believe I read that participations are exempt from CIP rules

2) Lending to the CDFI (rather than purchasing a participation, we provide a line of credit)
- Again, do we need to treat the end borrower as our customer if they are known? What is our responsibility if they are not known at the time we close our loan to the CDFI?

3) Fund investments (e.g., we make equity investment with real estate fund that lends to/invests with affordable housing developers)
-Are we required to do a review of the end borrower or just the entity that manages the fund?

Thanks for any input you can provide!