TOPIC: OFAC

OFAC Searches for Finance Company

Manager at a bank ($8.4BUSA)
We have a customer that does sales financing for large semi trucks.  The entity has a manufacturing arm, and finance arm.  we are banking the finance arm.  They request a tranche loan disbursement and use that to finance their individual customers (both entities and individuals).  Question - should the finance company (our customer) run an OFAC check on their customers who are purchasing the trucks?  If they don't currently run OFAC - should we as the FI require them to do this? They are not able to use the credit report OFAC flag, they do not subscribe to that service.  I am curious to see how other FI's handle this type of situation.