OFAC STATEMENT

Checking the Office of Foreign Assets Control (“OFAC”) List

If so required by law, before opening an account, and on an ongoing basis, we will check to ensure that a customer does not appear on Treasury’s OFAC “Specifically Designated Nationals and Blocked Persons” List (SDN List) (See the OFAC Web Site at http://www.treas.gov/ofac , which is also available through an automated search tool on http://www.nasdr.com/money.asp ), and is not from, or engaging in transactions with people or entities from, embargoed countries and regions listed on the OFAC Web Site. Because the OFAC Web Site is updated frequently, we will consult the list on a regular basis and subscribe to receive updates when they occur.
We may access these lists through various software programs to ensure speed and accuracy. We will also review existing accounts against these lists when they are updated and we will document our review.

In the event that we determine a customer, or someone with or for whom the customer is transacting, is on the SDN List or is from or engaging in transactions with a person or entity located in an embargoed country or region, we will reject the transaction and/or block the customer’s assets and file a blocked assets and/or rejected transaction form with OFAC. We will also call the OFAC Hotline at 1-800-540-6322.

ADOPTED 20 MARCH 2019

We may also use https://sanctionssearch.ofac.treas.gov/ to determine if an individual on on the SDN list.