American workers are scared of being perceived as anything else other than a YES MAN. The guy being told he has two-three days to implement OFAC can't say NO or they'll find someone to replace him that will say YES so he'll implement the shortest answer that causes that 'feature' to be marked as 'complete'
Even a random Excel geek would know that a "name" field is not the place to go for OFAC implementation. Or at least, not for a restaurant. I'm sure that they can link to corporate and banking data.
It doesn't really matter what someone knows, what matters is the payoff matrix:
Apply OFAC blacklisting extremely overly aggressively ... suffer an insignificant number of pissed off customers (who probably don't even leave you because everyone else is also awful).
Apply it as non-agressively as you think the law permits, or somewhat more than that... and find out that you're facing criminal charges because a prosecutor thinks the line was slightly different where you thought it was.
The situation is made more complicated in part because if prosecution isn't aggressive there are enormous sums of money ready to flow through whatever loophole exists and plenty of _bankers_ happy to help guide clients in blacklisted places through them. [ https://www.nytimes.com/2019/04/09/business/standard-charter... ]