Remember that you are doing the OFAC on the Customer, not the account. If you have already done the OFAC scan, and your system scans all customers each night, to catch the OFAC updates, then an additional OFAC check when opening a new account would not be necessary.
If your procedures/policy states that an OFAC check must be done on each new account opened, then you will need to get those changed.
(I also saw your ACAMS listserve message, but it is easier to answer here)
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CAMS, AMLP, AKC, K-9