To help the government fight the funding of terrorism and money laundering activities, federal law requires all financial institutions to obtain, verify and record information that identifies each person who opens an account.

What this means for individuals: When an individual opens an account, we will ask for your name, address, tax identification number, date of birth (as applicable) and other information that will allow us to identify you. We may also ask to see a government-issued photo ID or other identifying documents.

What this means for other legal entities: When a corporation, partnership, trust or other legal entity opens an account or requests credit, we will ask for the entity’s name, physical address, tax identification number and other information that will enable us to identify the entity. We may also request other information such as principal place of business, local office, certified articles of incorporation, government-issued business license, partnership agreement, or title and signature pages of a trust agreement

U.S. Department of Treasury, Securities and Exchange Commission, and/or FINRA rules already require you to provide most of this information. These rules also may require you to provide additional information, employment information, investment experience and objectives and risk tolerance. If you do not provide the information requested or we are unable to verify your identity, then we may not be able to open an account or carry out transactions for you. If you have already opened an account, we may have to close it.

Unlawful Internet Gambling Enforcement Act (UIGEA)

It is RBC Capital Markets, LLC’s and RBC U.S. Bank Network’s (collectively, "RBCCM") policy to comply with the U.S. Government regulations implementing the Unlawful Internet Gambling Enforcement Act of 2006 (UIGEA), U.S Federal law. Accordingly any account opened or maintained at RBCCM may not be used to process internet gambling transactions restricted by U.S. law. 1

USA Patriot Act – Section 311

Pursuant to U.S. regulations issued under Section 311 of the USA PATRIOT Act, RBCCM is prohibited from opening or maintaining a correspondent relationship for, or on behalf of, Commercial Bank of Syria or any of its subsidiaries (including Syrian Lebanese Commercial Bank), VEF Bank (Republic of Latvia) or any of its subsidiaries (including Veikmes Lizings), Banco Delta Asia or any of its subsidiaries, Myanmar Mayflower Bank and/or Asia Wealth Bank. Please note that the Entity’s relationship with RBCCM may not be used to provide any of these institutions with access to RBCCM. If RBCCM becomes aware that any of the aforementioned entities, or any entity or area listed by the U.S. Treasury Department as a “Primary Money Laundering Concern” is indirectly using the relationship held in the Entity’s name at RBCCM, RBCCM will be required to take appropriate steps to prevent such access, up to and including terminating the relationship. A list of areas or entities designated under the regulations may be reviewed on the U.S. Treasury’s Financial Crimes Enforcement Network website

Office of Foreign Assets Control (OFAC)

It is the policy of RBCCM to comply with sanctions administered by the U.S. Treasury’s Office of Foreign Assets Control (“OFAC”) which prohibit, among other things, the engagement in transactions with, and the provision of services to, certain countries, territories, entities and individuals (collectively, “OFAC Targets”). The lists of OFAC prohibited countries, territories, persons and entities can be found on the OFAC website. By commencing the relationship the Entity agrees, and will be deemed to have agreed, not to use the relationship with RBCCM to facilitate business with any OFAC Targets.

Please note that RBCCM may take whatever actions at its sole discretion, it considers necessary or appropriate to comply with anti-money laundering related laws, rules, regulations, sanctions and/or other applicable guidance. Such actions may include, but are not limited to, requests for additional information, and limitations or restrictions on the management and/or transfer of assets. The delay and/or failure to produce any information reasonably requested by RBCCM may result in the restriction and/or termination of the account or relationship with RBCCM. By commencing the relationship the Entity acknowledges and agrees to hold RBCCM harmless in connection with any loss arising from the restriction and/or termination of the relationship for the foregoing reasons.

[1] UIGEA’s definition of ‘unlawful Internet gambling’ states that it refers to a bet or wager that is ‘unlawful under any applicable Federal or State law in the State or Tribal land in which the bet or wager is initiated, received, or otherwise made’.