OFAC

As you are aware, Bancaribe Curaçao Bank, N.V. (the “Bank”) is a financial institution located and operating in Curaçao. To process your transactions in U.S. dollars, we maintain various banking correspondent relationships with U.S. financial institutions. As such, the Bank must comply with several laws and regulations of the United States of America, including, among others, the regulations promulgated by the Office of Foreign Assets Control of the U.S. Treasury Department (“OFAC”).

OFAC applies economic and trade sanctions against certain countries (“Sanctioned Countries”)1, as well as against terrorists and international drug traffickers who engage in activities that threaten national security, foreign policy, or the economy of the United States of America (collectively referred to as “Specially Designated Nationals”).

In general, OFAC regulations prohibit U.S. financial institutions from conducting or processing any financial transactions associated with Sanctioned Countries and/or involving assets or property of Specially Designated Nationals. These controls apply to deposits, contracts, letters of credit, fund transfers, payments, etc. In accordance with OFAC regulations, the Bank must block (freeze) or reject any transaction/transfer that is, directly or indirectly, associated with Specially Designated Nationals and/or Sanctioned Countries.

We recommend that you carefully review the sanctions related to Venezuela, as well as the supplemental information, general licenses, and materials published by OFAC that are available at: https://www.treasury.gov/resource-center/sanctions/Programs/pages/venezuela.aspx. We also recommend that you thoroughly review the Frequently Asked Questions about sanctions related to Venezuela published by OFAC that are available at: https://www.treasury.gov/resource-center/faqs/Sanctions/Pages/faq_other.aspx#venezuela. Finally, OFAC regulations and associated sanctions are updated and/or modified periodically. Since the Bank is not responsible for keeping you informed of such changes, we suggest that you periodically check the OFAC website at www.treasury.gov/ofac for updated information on applicable sanctions, as such changes may affect your transactions and the actions the Bank must take as a result.

1. For more information regarding Sanctioned Countries, please refer to the OFAC website at www.treas.gov/ofac.
2. The term “Government of Venezuela” includes the state and Government of Venezuela, any political subdivision, agency, or instrumentality thereof, including the Central Bank of Venezuela and Petróleos de Venezuela, SA (PdVSA), any person owned or controlled, directly or indirectly, by the foregoing, and any person who has acted or purported to act, directly or indirectly, on behalf of any of the foregoing, including as a member of the Maduro regime.
3. https://www.treasury.gov/resource-center/sanctions/Programs/Documents/venezuela_gl34a.pdf