Answer:
by Brian Crow:
OFAC does not mandate when and on whom a search is to be performed. It imposes penalties if you conduct a transaction for a sanctioned person. Your OFAC risk assessment should dictate when searches are to be performed. From a risk-based perspective, I do not see a good reason for excluding minors as there is nothing preventing the US Treasury from adding a minor to the OFAC list.
Answer:
by Andy Zavoina:
If your bank has good systems and successfully trained staff to do the OFAC checks, why muddle up a sound process with an exception which still carries risk with it, albeit a minor amount?
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