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Regulatory disclosures

Anti-Money Laundering Compliance

To help the U.S. government fight the funding of terrorism and money laundering activities, Federal law requires all financial institutions to obtain, verify, and record information that identifies each person who opens an account.

What this means for you:  When you open an account, we will ask for your name, address, date of birth for individuals, and any other information that will allow us to identify you. In certain situations we may also ask to see a form of identification with your photograph, for entities we may ask to see formative documents, for private investment vehicles and trusts we may ask to see evidence of source of funds and beneficial ownership or other identifying documents.

Notice to All Customers Regarding the Unlawful Internet Gambling Enforcement Act of 2006

The Unlawful Internet Gambling Act (UIGEA) of 2006 prohibits Société Générale, New York Branch and its affiliates, including SGAS, from processing restricted transactions. Restricted transactions are transactions in which a person accepts credit, funds, instruments or other proceeds from another person in connection with unlawful Internet gambling.

The UIGEA, signed into law in 2006, prohibits any person engaged in the business of betting or wagering (as defined in the Act) from knowingly accepting payments in connection with the participation of another person in unlawful Internet gambling. The United States Department of the Treasury and the Federal Reserve Board has issued a joint final rule, Regulation GG, to implement this Act.

As defined in Regulation GG, unlawful Internet gambling means to “place, receive or otherwise knowingly transmit a bet or wager by any means which involves the use, at least in part, of the Internet where such bet or wager is unlawful under any applicable Federal or State law in the State or Tribal lands in which the bet or wager is initiated, received or otherwise made.

Special Measures (Section 311) Customer Notification

The U.S. Department of the Treasury requires all U.S. banks to notify their customers as follows: Pursuant to U.S. regulations issued under Section 311 of the USA PATRIOT Act, 31 CFR 1010.655, 1010.653, and 1010.658, we are prohibited from opening or maintaining a correspondent account for, or on behalf of, Banco Delta Asia SARL or any of its subsidiaries (including Delta Asia Credit Limited and Delta Asia Insurance Limited; the Commercial Bank of Syria or any of its subsidiaries (including Syrian Lebanese Commercial Bank); and/or FBME Bank, Ltd. or any of its branches, offices, or subsidiaries. The regulations also require us to notify you that your correspondent account with our financial institution may not be used to provide Banco Delta Asia SARL or any of its subsidiaries; Commercial Bank of Syria or any of its subsidiaries; or FBME Bank, Ltd. or any of its branches, offices, or subsidiaries. If we become aware that Banco Delta Asia SARL or any of its subsidiaries; Commercial Bank of Syria or any of its subsidiaries; or FBME Bank, Ltd. or any of its branches, offices, or subsidiaries are indirectly using the correspondent account you hold at our financial institution, we will be required to take appropriate steps to prevent such access, including terminating your account.

Office of Foreign Assets Control

Please be advised that your activities with SG are subject to all applicable law, including laws issued and enforced by the Office of Foreign Assets Control (“OFAC”).