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It is highly unlikely, but not impossible. Anecdotally, I did see a case of a business that put a real location of the business they are working with, which happened to be in a sanctioned country. Needless to say, it generated all sorts of questions and eventual OFAC contact.

Bottom line is: it happens, but I agree with you that people that know what they are doing are not putting "Pay for assasination by Osama Bin Laden on 03/28/23" in reference field.



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