Running OFAC Checks on Non-Member Cash Advances

Question - I have a concern about Office of Foreign Assets Control (OFAC) compliance. Do we need to run names against the OFAC list if we give a cash advance to a non-member on their Visa card? According to our contract with Visa, we have to offer this service even if the card is not from our credit union. We currently run OFAC for all loan disbursements to non-members but our credit union is not the holder of the loan in this case so there is an argument that running OFAC is not necessary. What is the best procedure here?

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