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Patriot Act Compliance

Reporting Specially Designated Nationals (SDN) to the Office of Foreign Assets Control (OFAC):

1. If Distributors or Customers appear on one of your SDN List Check reports, you must evaluate the quality of the match. Compare the name of the Distributor/Customer with the name on the SDN list. Is the Distributor/Customer name an individual while the name on the SDN list is a vessel, organization or company (or vice-versa)?

A. If yes, you do not have a valid match.*

B. If no, please continue to 2 below.

2. How much of the SDN’s name is matching against the Distributor/Customer name? Is just one of two or more names matching (i.e., just the last name)?

A. If yes, you do not have a valid match.*

B. If no, please continue to 3 below.

3. Compare the complete SDN entry with all of the information you have on the matching name in the Distributor/Customer profile. An SDN entry often will have, for example, a full name, address, nationality, passport, tax ID or cedula number, place of birth, date of birth, former names and aliases. Are you missing a lot of this information on the Distributor/Customer profile?

A. If yes, go back and get more information and then compare your complete information against the SDN entry.

B. If no, please continue to 4 below.

4. Are there a number of similarities or exact matches?

A. If yes, please call the hotline at 1-800-540-6322.

B. If no, you do not have a valid match.*

* If you have reason to know or believe that operating with this Distributor/Customer would violate any OFAC Regulations, you must call the hotline and explain this knowledge or belief.

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