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.