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OFAC Statement
OFAC/Sanctions Policy
Last updated: 12/27/2020

This Policy assures our compliance with the U.S. Department of the Treasury, Office of Foreign Assets Control (OFAC) laws and regulations regarding economic and trade sanctions in jurisdictions where does business. Economic and trade sanctions are based on foreign policy and national security goals. 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 In addition to the programs administered by OFAC, the U.S. Department of Commerce and Department of State administer 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 entities do business may have sanction screening and other requirements applicable to our operations.

OFAC maintains and publishes a list of countries, people, and organizations that are subject to sanction.

Other jurisdictions where entities do business may publish similar lists indicating those 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 data against applicable Sanction Target lists.