Answer:
If the authorized user is on the SDN list, I think you'd have an OFAC problem. Whether you screen for that or not is a risk call on your institution's part.
Business Title CC-Authorized Users OFAC
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Question:
We issue credit cards with our bank branding using an outside processor. When a business opens a credit card account and has cards issued to authorized users, who is our customer for OFAC purposes? Any card would be issued with titling of ABC Company John Doe embossed on the card. We currently run OFAC for the business but, not the authorized user.
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