we have told the customer contact folks that any business with more than 3 owners need to take their business elsewhere.
That's a pretty extreme over reaction.
There is an ANPRM on this subject, but as of today there is only guidance that suggests you should identify beneficial owners of high risk customers. As noted OFAC searches are risk based and someone would have to own 51% of an entity for a hit on that person to constitute a hit on the entity. 314(a) searches are rules based and, without going into detail in a public forum, would not require you to search on owners.
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