We currently complete an OFAC check on those non-customers and capture their identification and add them to our core processor in which a periodic OFAC check is completed. We also scan the initial verification along with the customers ID and retain on our network in the event an examiner would want to verify. I think this is an unnecessary step as once the information is in the system and OFAC checks are completed periodically against all the names in our database.

Curious at to what other banks may be doing.

There's no regulations regarding the frequency of OFAC verification. I think it's a bit overkill and our OFAC system keeps electronic record of the verification.

I assume you are talking about when you cash an on-us check for a non-customer. Have you considered just applying a stamp to the face of the check that says "OFAC Verified?" You can still enter the non-customer's information in your system. But the scanning of the ID and initial verification really isn't necessary if you can prove to an examiner that information is retained in the core.

Performing an OFAC verification on the payee of a check is a risk-based decision as ramblings stated.