OFAC/Sanctions Policy

Purpose

This policy assures our compliance with the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) laws and regulations as well as applicable law regarding economic and trade sanctions in jurisdictions where Principal does business. Economic and trade sanctions are based on foreign policy and national security goals of the jurisdiction issuing the sanction regime.

These sanctions may be against targeted foreign countries and regimes, terrorists, international narcotics traffickers, those engaged in activities related to the proliferation of weapons of mass destruction, and other threats to the national security, foreign policy, or economy of the applicable jurisdiction.

Policy Statement

OFAC administers and enforces economic and trade sanctions. In addition to the programs administered by OFAC, the U.S. Department of Commerce and Department of State also have programs that include visa restrictions and export controls of certain goods and technology (including encryption, non-publicly available software, computers, and network equipment, among other items). Depending on the item involved and the intended destination, end user, or use, a license may be required prior to export or the exportation may be prohibited. Additionally, the jurisdictions where Principal entities do business may have sanction screening, export controls, and other requirements applicable to our operations.

OFAC maintains and publishes a list of people and organizations that are subject to sanction. OFAC also maintains tailored sanctions programs that apply to specific countries. In certain instances, the country-based sanctions are broad enough that the country is regarded as “comprehensively sanctioned” and Principal is not allowed to conduct business with, or disburse funds to, people or organizations located in that country. Other jurisdictions where Principal entities do business may publish similar lists indicating people, organizations, and countries subject to sanctions. Those named by OFAC or other applicable jurisdictions, are together referred to as “Sanctions Targets.” We’ve implemented procedures for the screening of customers, business associates/vendors, payees, and other applicable Principal data against applicable Sanction Target lists.

U.S. persons and U.S. entities must comply with OFAC regulations regardless of where they’re located in the world. In the case of certain OFAC enforced sanctions, foreign subsidiaries owned or controlled by U.S. companies may also be required to comply.

Our companies have a legal obligation to avoid doing business with or engaging in prohibited transactions with Sanctions Targets, and act as required by OFAC or other applicable regulations in the jurisdictions we do business. This may include freezing accounts, blocking payments, and filing necessary reports with regulatory authorities. Compliance with this policy, OFAC, or other applicable sanctions is essential to protect Principal against criminal and civil penalties and to maintain our reputation and trust of our customers.