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Replies to post #966 on Francisco Industries, Inc. (FRAZ)
Third-country financial institutions, including Montreal, Canada-based National Bank of Canada (2018 assets approximately US$250 billion) and those located on the European Continent, provide payment facilitation services for purchases made by Republic of Cuba government-operated Empresa Cubana Importadora de Alimentos (Alimport). Third-parties have received fees on nearly all of the US$5.9 billion in TSREEA-related transactions.
Our banking relationships with the Cuban government and Banco Internacional de Comercia, S.A. (“BICSA”) may increase our compliance risk and compliance costs. U.S. persons, including U.S. banks, are restricted in their ability to establish relationships and engage in transactions with Cuba and Cuban persons pursuant to the existing U.S. embargo and the Cuban Assets Control Regulations. However, as a result of our acquisition of Stonegate Bank in 2017, we maintain a customer relationship to handle the accounts for Cuba’s diplomatic missions at the United Nations and for the Cuban Interests Section (now the Cuban Embassy) in Washington, D.C. This relationship was established in May 2015 pursuant to a special license granted to Stonegate Bank by the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) in connection with the reestablishment of diplomatic relations between the U.S. and Cuba. In July 2015, Stonegate Bank established a correspondent banking relationship with Banco Internacional de Comercio, S.A. (“BICSA”) in Havana, Cuba.
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