In a loan transaction, who should be checked against the OFAC list. Our bank checks our customer, guarantors, etc. and that’s it. I’m concerned that we should be checking any individual or entity that receives loan proceeds (car dealer, debt collector, other businesses, etc).
I believe you are correct, you should be checking everyone involved in the transaction, including those receiving proceeds. OFAC is to limit US companies from conducting business with certain people and giving them proceeds would be conducting business with them.