Answer:
There is not a specific requirement to check any name. Which names you choose to check and for what purposes are dependent on your OFAC risk assessment. You need to look at what the risks are of doing business with someone on the OFAC SDN list and weigh that against the cost to check to make sure they're not. Whatever decision you reach should be documented in your risk assessment with the rationale for that decision.
First published on BankersOnline.com 1/15/07