Answer:
There are no OFAC regs that require comparing names of potential or existing customer to the OFAC lists; however, there is a prohibition from doing business with any entity on the lists. As a result, it's a risk based decision made by each institution as to how to handle that comparison. If your institution's OFAC process does not include a specific exemption from comparing the names of children under a certain age, but instead requires the comparison on all parties to an account, that's reason enough to have to verify individuals even if they are children.
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