edit: Tbh. The more I think about it, maybe it is not such a far fetched idea after all with the assumption that they keys are temporary.
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Eh. Coming from that environment, it would not be that easy for a reason that has nothing to do with technology. The lists that financial companies use are largely known ( some published by US Treasury for everyone to use ) and you can reasonably estimate a threshold most institutions will find acceptable.
However, the issue is political and not technical. OFAC itself has grown its SDN list[1] to 6300 names and that is just one list and the tool has been already severely overutilized ( in my opinion anyway, so take that with a grain of salt ), but if the trend and current geopolitical situation is any guide, this number will only increase.
What I am saying is that you have a big and very variable base to build a key from ( edit: come to think of it - not from:P ) and there is no guarantee and old key won't suddenly become 'hot'.
Here, the answer is to the problem is actually political. Affected businesses have to start really complaining, if they are affected by the requirements. I have no evidence suggesting that is the case ( based on what I saw maybe 20% of transactions face that kind of scrutiny and even smaller percentage is questioned the way the OP is ). Naturally, it does not help that this process is not standardized so every single financial institution does their own thing..
[1]https://home.treasury.gov/policy-issues/financial-sanctions/...