JPMorgan Chase & Co., including its non-U.S. branches and subsidiaries, (“JPMC”) must comply with the sanctions administered and enforced by the Office of Foreign Assets Control of the U.S. Department of the Treasury (“OFAC”) (http://www.treasury.gov/about/organizational-structure/offices/Pages/Office-of-Foreign-Assets-Control.aspx) and any other related U.S. laws and regulatory requirements, whether as a matter of law or JPMC policy. In addition, the European Union (“EU”) maintains sanctions and restrictive measures which apply across all its member states and, therefore, JPMC entities operating within the EU must comply with EU sanctions programs (http://eeas.europa.eu/cfsp/sanctions/index_en.htm). Other countries where JPMC entities operate may also impose sanctions restrictions with which JPMC must comply.
OFAC sanctions prohibit or restrict JPMC from engaging in activity that involves sanctioned persons or comprehensively sanctioned countries and regions. Depending on the particular sanctions, JPMC may be required to freeze assets, reject transactions, not extend credit or provide services, or take other specific actions. With respect to comprehensively sanctioned countries and regions—currently the Crimea region, Cuba, Iran, North Korea and Syria—JPMC is prohibited from engaging in or facilitating transactions that have any connection to these countries or region, unless such activity is exempt from the prohibitions or is subject to a general or specific OFAC license.
Except as specifically authorized or permitted by OFAC and other applicable sanctions regulations, JPMC customers must ensure that none of their investments, services, goods or trade involving sanctioned persons, countries or regions are sent to or processed through JPMC, or are funded or otherwise facilitated by financing provided by JPMC. JPMC will take appropriate action, including potentially blocking (i.e., freezing) or rejecting funds, with respect to transactions that appear to violate applicable sanctions.