US Anti-Money Laundering Compliance

To help the 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, and for private investment vehicles and trusts we may ask to see evidence of source of funds and beneficial ownership or other identifying documents.

The Unlawful Internet Gambling Act (“UIGEA”) of 2006 prohibits Société Générale, New York Branch 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 have 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.

Pursuant to U.S. regulations issued under Section 311 of the USA PATRIOT Act, 31 CFR 1010, Subpart F (“Section 311 Special Measures”), Société Générale’s U.S. operations (“SGUS”) are prohibited from establishing, maintaining, administering, or managing an account for, or on behalf of the following entities (“Section 311 Entities”) identified by the U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”). Section 311 Special Measures regulations also require SGUS to notify you that your account with our financial institution may not be used to provide services to or on behalf of, or involve, any of the Section 311 Entities. If we become aware that any of the Section 311 Entities is found to be directly or indirectly using or accessing the account you hold at our financial institution, we will be required to take appropriate steps to prevent such access, including, where necessary, terminating your account.

The list of financial institutions identified by FinCEN as Section 311 Entities for which FinCEN has issued a notice of finding, notice of proposed rulemaking or a final rule is as follows:

• Bank of Dandong Co., Ltd. or any of its branches, offices or subsidiaries
• FBME Bank Ltd, formerly known as the Federal Bank of the Middle East, Ltd. or any of its branches, offices or subsidiaries
• Commercial Bank of Syria (CBS) or any of its branches, offices or subsidiaries, including Syrian Lebanese Commercial Bank
• Any financial institution of Burma except to the extent permitted by 31 CFR 1010.970
• Any financial institution of the Democratic People’s Republic of Korea (DPKR or North Korea)
• Any financial institution of the Islamic Republic of Iran
• Halawi Exchange Co.
• Kassem Rmeiyi & Co. For Exchange
• ABLV Bank
• Al-Huda Bank

We may from time to time apprise you of additional Section 311 Entities that are added to this list as new restrictions are proposed or issued.

SGUS must comply with the sanctions administered and enforced by the Office of Foreign Assets Control of the U.S. Department of the Treasury (“OFAC”) (https://www.treasury.gov/about/organizational-structure/offices/Pages/Office-of-Foreign-Assets-Control.aspx) and any other related U.S. laws and regulatory requirements, whether as a matter of law or SGUS policy.  In addition, SGUS complies with the European Union (“EU”) sanctions and restrictive measures which apply across all its member states (https://eeas.europa.eu/cfsp/sanctions/index_en.htm), as well as sanctions imposed by the United Nations.

OFAC sanctions prohibit or restrict SGUS from engaging in activity that involves sanctioned persons or comprehensively sanctioned countries and regions. Depending on the particular sanctions regime, SGUS may be required to freeze assets, reject transactions, not extend credit or provide services, including financial services, or take other specific actions. SGUS is prohibited from engaging in or facilitating transactions that have any connection to sanctioned person or countries or regions, unless such activity is exempt from the prohibitions or is subject to a general or specific OFAC license.  Except as specifically authorized or permitted by OFAC and other applicable sanctions laws and regulations, SGUS customers must ensure that none of their investments, services, goods or trade involving sanctioned persons, countries or regions are sent to or processed through SGUS, or are funded or otherwise facilitated by financing provided by SGUS. SGUS will take appropriate action, including potentially blocking (i.e., freezing) or rejecting funds, with respect to transactions that appear to violate applicable sanctions laws and regulations.