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.

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 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.

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 USC 5318A, SGUS is prohibited from establishing, maintaining, administering, or managing an account for, or on behalf of: Iranian financial institutions as defined in 31 CFR 1010.661(a); ABLV Bank or any of its branches, offices, and subsidiaries; Bank of Dandong or any of its branches, offices, and subsidiaries; the Commercial Bank of Syria or any of its branches, offices, or subsidiaries (including Syrian Lebanese Commercial Bank); North Korean banking or financial institutions as defined in 31 CFR 1010.659; and/or FBME Bank, Ltd. or any of its branches, offices, and subsidiaries (collectively “Section 311 Entities”). The regulations also require us 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 any Section 311 Entities are found to be 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 terminating your account

Office of Foreign Assets Control

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”) (http://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 (http://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.