Answer:
There is not now, nor has there ever been an explicit requirement for banks to check the OFAC list. It is a "risk based" decision that varies from bank to bank. Your bank is entitled to make its own decision about whether it is necessary to incorporate middle names or initials in its searches.
I would make the observation that you are not assuming more risk when you fail to use the initial or middle name, you are simply increasing the risk that you will get a "false positive" and waste time discounting the match.
First published on BankersOnline.com 12/10/12
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