Outgoing wire request being sent by a bank customer to Aerospace business in Germany. In the "Comments" section of wire request there are details regarding PO#, Quote # and Contact Name. Two individuals are listed in the contact name field. There were two potential OFAC matches that hit on the first name of one individual (Nico). To satisfactorily clear this should we be running OFAC on these "contact names" listed in the wire request? They are not the names of the originator or the beneficiary of the wire.

What you run OFAC on is a business decision. I am not sure why a first name match only would be of any concern. I am also not sure why you would not run one on any identified party on an international wire.