1. Created by American Express Singapore Compliance Office July 2003 S ANCTIONS

2. A GENDA n Background n Application of sanctions n Q&A

3. S ANCTIONS A GENDA n Background n Application of sanctions n Q&A

4. S ANCTIONS W hat A re U.S. S anctions? A series of trade restrictions imposed by the US government on: n US nationals n US companies and their branches n Non-US companies owned by US companies n Non-US companies controlled by US companies n Non-US companies located in US

5. S ANCTIONS L ist of S anction C ountries n Cuba n Iran n Iraq n Libya n Sudan n North Korea n Syria n Afghanistan (The Taliban) n Yugoslavia (Serbia)

6. S ANCTIONS B asic C ompliance R ules These sanctions mean that generally... n All staffs may not participate in certain business and travel transactions involving sanction countries or individuals or organizations. n All staffs must follow the rules strictly even under pressure from customers to terminate relationship with Amex. n No staff, however senior, has authority to break rules or grant exceptions for any client.

7. S ANCTIONS P enalties Breaking sanctions rules means... n Monetary fines as high as USD10 million for corporations and USD250 thousand for individuals n Civil penalties as high as USD1 million n Imprisonment up to 30 years n Disciplinary actions n Negative publicity n Damage to Amex and our brand

8. S ANCTIONS R egulatory B ackground U.S. laws n Trading With The Enemy Act n Emergency Economic Powers Act n Anti-terrorism and Effective Death Penalty Act Singapore laws n MAS (Anti-terrorism measures) regulations implement the United Nations Security Council resolutions on anti-terrorism measures.

9. S ANCTIONS A GENDA n Background n Application of sanctions n Q&A

10. S ANCTIONS SDN, SDT, SDGT, FTO, SDNTK, Balkan, Taliban and Zimb You cannot carry out any transaction or service in which an SDN, SDT, SDGT, FTO, SDNTK, SDNT, Balkan, Tabliban, or Zimb is involved. Definitions: n SDN = Specially Designated Nationals n SDT = Specially Designated Terrorists n SDGT = Specially Designated Global Terrorists n FTO = Foreign Terrorist Organizations n SDNTK = Specially Designated Narcotics Trafficker Kingpin n SDNT = Specially Designated Narcotics Trafficker

11. S ANCTIONS G overnment of S anction C ountries You cannot carry out any transaction for a person or organisation that is part of, or owned, or controlled by governments of all sanction countries. Above prohibitions are not applicable to: n North Korea n Syria n Afghanistan (The Taliban) n Yugoslavia (Serbia) Restriction only on donation from government / transaction supporting terrorism Restriction only on transaction associated with former Taliban / Balkan

12. S ANCTIONS N ationals of S anction C ountries You can carry out a transaction or service for nationals of sanction countries ONLY if the nationals are outside the sanction countries at time transactions occur or services are provided. Above prohibitions are not applicable to: n North Korea n Syria n Afghanistan n Yugoslavia n Iraq You cannot carry out any transaction or service for Cuban national (regardless of where the individual is resident) or member of an organization based in Cuba.

13. S ANCTIONS Part 1 - C ard A pplication New Accounts received a card application but noticed that the billing address is in Iran. Upon investigation, Amy found out that the card applicant, Luta, is a Singaporean who will be posted to Iran for the next 1 year due to his job requirement. The primary reason he applied for the card is to give his wife a supplementary card for use in Singapore. He provided an Iranian address so that he can receive his statement in Iran and pay for the card charges.

14. S ANCTIONS Part 2 - C ard P ayment A rrangement Amy checked and verified that Luta is not a sanctioned individual. However, she knew that Iran is a sanction country and to ensure Amex has no dealings with any sanction country, Amy asked Luta whether he would mind if the card statements were sent to his wife in Singapore. Luta agreed and provided Amy with his Singapore residential address. However, he told Amy that since his wife is not working, the card charges will be settled via fund transfer from his account with Iran National Bank, the like of Singapore POSB.

15. S ANCTIONS A few months later, while Luta is on a business trip to Afghanistan, he was robbed and lost his wallet. He called Amex, explained the purpose of his call for a card replacement. TSC staff, Janet, expressed sympathy and promised that his replacement card will be sent to his hotel in Afghanistan in a week’s time. Luta told Janet that he will be leaving for Iran after 3 days and requested the replacement card be sent to his Iranian residential address instead. Janet took down the address and proceed with the standard card replacement procedures. Part 3 - C ard R eplacement

16. S ANCTIONS C ard A pplication / C ancellation You cannot: (1) approve new card application with billing address in sanction countries; cardmembers must be cancelled, (2) solicit cardmember for alternate billing address. Above prohibitions are not applicable to: n North Korea n Syria n Afghanistan n Yugoslavia n Iraq For Cuban resident or national residing anywhere in the world, you cannot: (1) approve a new card application; cardmembers must be cancelled, (2) solicit billing address outside Cuba.

17. S ANCTIONS C ard P ayment You cannot accept: (1) sanctioned currency, (2) fund transfer from banks in sanction countries or their government-owned/controlled banks. Above prohibitions are not applicable to: n North Korea n Syria n Afghanistan n Yugoslavia

18. S ANCTIONS C ard R eplacement You cannot perform card replacement to sanction countries. Above prohibitions are not applicable to: n North Korea n Syria n Afghanistan n Yugoslavia n Iraq

19. S ANCTIONS A GENDA n Background n Application of sanctions n Q&A