Answer:
It would be illegal for you to pay an individual on the SDN list. Undoubtedly, your HR department obtains each applicant's written authorization to run a credit bureau check. Many such checks automatically include a pass of the OFAC list and will flag reports when a match (or possible match) is detected. If the bureau checks you are running are doing that, you're already taking care of the OFAC check and your HR director may not realize it.
First published on BankersOnline.com 8/27/07