Corporate Compliance Program. 13. SCB represents that it has implemented and will continue to implement a compliance program designed to prevent and detect violations of U.S. economic sanctions laws and regulations, including IEEPA, throughout its operations, including the operations of SCB’s subsidiaries, affiliates, and majority-owned or controlled joint ventures whose operations include managing client accounts for clients subject to sanctions administered by OFAC, processing payments denominated in U.S. dollars (“USD”), and directly or indirectly supervising such operations. In order to address any deficiencies in its sanctions compliance program, SCB represents that it has undertaken, and will continue to undertake in the future, the following sanctions compliance obligations:
Appears in 4 contracts
Samples: Deferred Prosecution Agreement, Deferred Prosecution Agreement, Amended Deferred Prosecution Agreement
