OFAC/Sanctions Policy

Last updated: 4/27/2020

Purpose

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 Principal 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 Principal 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 Principal 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 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, such as those applying to Iran, foreign subsidiaries owned or controlled by US companies may also be required to comply. 

Our companies have a legal obligation to avoid doing business with Sanctions Targets, as required by applicable law, and act as required by OFAC or other applicable regulations. 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.