On February 24, OFAC designated ten additional Russian financial institutions to its Specially Designated Nationals and Blocked Persons ("SDN") List, including Credit Bank of Moscow PJSC, one of Russia's ten largest banks by asset value (and which already was subject to sectoral sanctions). Reporting. Refer to the expanded overview section, "Automated Clearing House Transactions," page 216, for additional guidance. Frequently Asked Questions". In these situations, the ODFI must exercise increased diligence to ensure that illegal transactions are not processed. United Kingdom. When developing OFAC policies, procedures, and processes, the bank should keep in mind that OFAC considers the continued operation of an account or the processing of transactions post-designation, along with the adequacy of The New Investment Ban EO prohibits new investment in Russia by a US person, wherever located, although the term new investment is not defined. Specific licenses are issued on a case-by-case basis. All U.S. persons, OFAC expects a business to have its own compliance program in place if it engages in certain behavior, including: Do not get caught doing business with someone on the list. A payment order cannot be canceled or amended after it is received by a U.S. bank in the absence of an authorization from OFAC. OFAC realizes that financial institutions use software that does not always provide an instantaneous response and may require some analysis to determine if a customer is indeed on OFAC's Specially Designated Nationals List (or any of OFAC's other sanctions lists). Prohibited transactions are trade or financial transactions and other dealings in which U.S. persons may not engage unless authorized by OFAC or expressly exempted by statute. All property and interests in property subject to U.S. jurisdiction of these persons are blocked, and U.S. persons The frequency of the review should be based on the banks OFAC risk. OFAC lists have not been designated government lists for purposes of the CIP rule. 501.603 and 501.604). 1. 52. This includes: U.S. banks Bank holding companies Nonbank subsidiaries. Specifically, you want to look at paragraphs 408 and 517. The SDN list was created primarily for financial institutions but, as it grows, its been increasingly used by insurance companies and international organizations. ACH transactions may involve persons or parties subject to the sanctions programs administered by OFAC. Blocked Transactions . General enquiries. Commercial letters of credit and other trade finance products. Banks are responsible for tracking the amount of blocked funds, the ownership of those funds, and interest paid on those funds. Financial institutions are subject to the prohibitions and reporting required by OFAC regulations. There is no legal or regulatory requirement to use software or to scan. L. No. Tipalti B.V. is not authorised by the Dutch Central Bank to process payments or issue e-money. What is the SDN list? All U.S. persons must comply with OFAC regulations, including all U.S. citizens and permanent resident aliens regardless of where they are located, all persons and entities within the United States, all U.S. incorporated entities and their foreign branches. Certain programs also require foreign persons in possession of U.S. origin goods to comply. sUE2:GD}Y}x}GQcuZ8(,tjEQWe5Z=qMh^G=h_1"ikXucu>a#>v]XE>VGUY,V((c:F a=1}DVFjUO#:V_>f_yY;o^7V]hG 8vnDWvcr6jG{(fU8jEUPXyu6j\_GVQZkic}D]yqjn]Oj{;Y|gj-{;koDloYpBIoi}VVT&ZG}vgX>WUH_WU_w=V}VmzpglVU_=^hWwcV}cs>V{j-wQ*>7k>V]WwfjVlOjnz5x9Vj97g In guidance issued on March 10, 2009, OFAC authorized institutions in the United States when they are acting as an ODFI/Gateway Operator (GO) for inbound IAT debits to reject transactions that appear to involve blockable property or property interests. If the transaction conforms to internal licensing policies and U.S foreign policy objectives, then the license is generally issued. 44. For blocked property (including blocked transactions), records must be maintained for the period the property is blocked and for five years after the date the property is unblocked. Every U.S. person and business must comply with OFAC regulations. Reg E, UCC4A, OFAC, etc.) The audit scope should be comprehensive enough to assess OFAC compliance risks and evaluate the adequacy of the OFAC compliance program. Reg. Although not a full list, some examples of products, services, customers, and geographic locations that have a high OFAC risk include: Every business should have controls in place that ensure compliance with OFAC regulations. OFAC expects banks to conduct due diligence on their own direct customers (including, for example, their ownership structure) to confirm that those customers are not persons whose property and interests in property are blocked. OFAC encourages banks to take a risk-based approach to designing and implementing an OFAC compliance program. Dollars or . Common Prohibited Transactions Making new investments in a country that is blocked or in property that a blocked government or Specially Designated National (SDN) owns, controls, or has an interest. Every point of contact should be a point to reverify or revalidate a payee. OFAC is a government agency within the U.S. Department of the Treasury. 2. Prohibited transactions that are rejected must also be reported to OFAC within 10 business days of the occurrence. Chapter X is comprised of a "General Provisions Part" and separate financial-institution-specific parts for those financial institutions subject to FinCEN regulations. So, even though a funds transfer between an American and Sudanese company isnt against U.S. sanctions, it goes against Sudanese laws; despite neither party being part of the Specially Designated Nationals (SDN) or blocked persons list. Transactions that are Subject to OFAC All of the following types of financial transactions should be reviewed for OFAC compliance: Deposit (checking & savings) accounts Loans Credit Cards Wire transfers ACH transfers Lines of credit Trust accounts Loan payments Letters of credit Currency exchanges Safety deposit boxes Depositing or cashing checks While not required by specific regulation, but as a matter of sound banking practice and in order to mitigate the risk of noncompliance with OFAC requirements, banks should establish and maintain an effective, written OFAC compliance program that is commensurate with their OFAC risk profile (based on products, services, customers, and geographic locations). 154License information for a particular sanction program is available on the OFAC Web site or by contacting OFAC's Licensing area at (202) 622-2480. To receive a specific license, a person or entity must submit an application to the OFAC. Bank of the West is an Equal Opportunity employer and proud to provide equal employment opportunity to all job seekers without regard to any status protected by applicable law. The procedure applies to transactions that would normally be blocked as well as to transactions that would normally be rejected for OFAC purposes based on the information in the payment. Every bank should conduct an independent test of its OFAC compliance program that is performed by the internal audit department, outside auditors, consultants, or other qualified independent parties. London. This will allow the bank to verify whether a customer is initiating a legal transaction. Block accounts and other property of specified countries, entities, and individuals. Payoneer vs Worldfirst: Comparing Global Money Transfer Platforms, What is SWIFT? With respect to cross-border screening, similar but somewhat more stringent OFAC obligations hold for International ACH transactions (IAT). Monitoring accounts to detect unusual or suspicious activity for example, unexplained significant changes in the value, volume, and types of assets within an account. Some enforcement responses may result in the issuance of a civil penalty that, depending on the sanctions program affected, may be as much as $250,000 per violation or twice the amount of a transaction, whichever is greater. In the case of cashier's checks, do I need to check both the purchaser and the payee? As global relations and events consistently change, the OFAC will continue to monitor and update the sanctions list. We've paired this article with a comprehensive guide to global payment methods. Questions about whether a transaction should be blocked or rejected should be directed to OFAC's Sanctions Compliance & Evaluation Division at OFACReport@treasury.gov. Donations to charitable institutions must be handled as any other financial transaction. [091002] OFAC's regulations are broader than the specific laws that deal with the terrorists and persons who support them. This is a significant departure given that both Sberbank and Alfa-Bank were subject to more limited sanctions in the past, including those under Executive Order 14024 of April 15, 2021. * This list is comprised of companies and individuals that are controlled or acting for other targeted groups or countries such as terrorists, narcotics traffickers, and foreign sanctions evaders. This is done through a concise licensing process and is determined when a transaction does not undermine U.S. policy objectives. The document explains the procedures that OFAC follows in determining the appropriate enforcement response to apparent violations of its regulations. And answer D, doesn't correlate to OFAC - Every transaction that a U.S. financial institution engages in is subject to OFAC regulations. Cross-border automated clearing house (ACH) transactions. Understand and comply with all applicable federal and state laws and banking regulations (including those related to OFAC and Bank Secrecy Act / Anti-Money Laundering compliance) and Patelco . Eunkyung advices clients on various regulatory compliance and trade issues, concentrating on the US export controls such as the Export Administration Regulations (EAR) and International Traffic in Arms Regulations (ITAR), economic and trade sanctions, US customs and import laws, the US Foreign Corrupt Practices Act (FCPA), and foreign anti-bribery laws. In this section of law, OFAC "sets forth standard reporting and recordkeeping requirements and license application and other procedures governing transactions regulated pursuant to other parts . However, since the SSR requires blocking transactions with the government of Sudan, and exportation of services to Sudan is prohibited, the U.S. bank cannot process the transaction and it is rejected. Every transaction that a U.S. financial institution engages in is subject to OFAC regulations. Many AP systems driven by business intelligence will give companies the option to flag bad actors themselves. Banks should also be aware of the expiration date on the OFAC license. Internal controls should include the following elements: Identifying and reviewing suspect transactions.The banks policies, procedures, and processes should address how the bank will identify and review transactions and accounts for possible OFAC violations, whether conducted manually, through interdiction software, or a combination of both. Full Blocking Sanctions on Sberbank and Alfa-Bank. Maintaining license information.OFAC recommends that banks consider maintaining copies of customers' OFAC licenses on file. OFAC can also promulgate general licenses, which authorize categories of transactions, such as allowing reasonable service charges on blocked accounts, without the need for case-by-case authorization from OFAC. What other rules and regulations pertain to IATs? In some cases, a transaction must be blocked, and in other cases, even though an underlying transaction may be prohibited, there may be no blockable interest in the transaction. OFAC encourages firms operating in the securities industry, including securities intermediaries and custodians, to implement measures that mitigate the risk of providing services to, or dealing in property in which there is an ownership or other interest of, parties subject to U.S. sanctions. In determining the frequency of OFAC checks and the filtering criteria used (e.g., name derivations), banks should consider the likelihood of incurring a violation and available technology. Every transaction that a U.S. financial institution does is subject to OFAC regulations. Every transaction that a United States financial institution engages in is subject to OFAC laws and regulations. According to the requirements of federal statutes and specific sanctions, in most cases, deposits and funds should be accepted then blocked or frozen to ensure funds cannot be withdrawn. Regulations also require screening of customer databases against the frequently updated OFAC list for potential matches to terrorists, drug traffickers and other sanctioned entities. Anyone who works with a vendor or individual that does not pass an OFAC check can be criminally charged and fined under federal law. OFAC reporting and recordkeeping requirements are specified in the Federal Register in 31 C.F.R. Brianna Blaney began her career in Boston as a fintech writer for a major corporation. After it is received, a payment order cannot be canceled or amended without an authorization from the OFAC. IAT does not change other regulations and rules that pertain to ACH transactions today. The OFAC also issues specific licenses on a case-by-case basis. 164Refer to the NACHA Web site. There is a requirement, however, not to violate the law by doing business with a target or failing to block property. Banks must keep a full and accurate record of each rejected transaction for at least five years after the date of the transaction. Company must determine if the individual is subject to OFAC actions. Onboarding any partner must involve a background check, including screening on OFAC watchlist databases for: Its also appropriate to consider the banking information the supplier provides for their remittance. We are not permitted to carry out regulated business activities. These types of changes may indicate that a customer is facilitating new business for third parties that has not been vetted for possible sanctions implications. Blocked and rejected transactions must be reported to OFAC within 10 days (see 31 C.F.R. Through corporate giving programs, many banks contribute toward charities and other non-profits. All updated financial sanctions of the OFAC are listed on the recent actions page. In these cases, the transaction is simply rejected, (i.e., not processed). ODFIs acting in this capacity should already know their customers for the purposes of OFAC and other regulatory requirements. Unlike the Bank Secrecy Act (BSA), OFAC laws and regulations dont just apply to U.S. persons and domestic agencies They also apply to foreign branches and overseas subsidiaries. If a bank handling a wire transfer currently has information in its possession leading the bank to know or have reason to know that a particular individual or entity involved with or referenced in the wire transfer is subject to blocking, then the bank will be held responsible if it does not take appropriate steps to ensure that the wire transfer is blocked. [09 -10-02] OFAC's regulations are broader than the specific laws that deal with the terrorists and persons who support them. Is there a dollar limit on which transactions are subject to OFAC regulations? 101-513, 104 Stat. 154Licensing information for a particular sanctions program can be found on the OFAC website or in the OfAC licensing section at (202) 622-2480. Beneficiaries include, but are not limited to, trustees, children, spouses, non-spouses, entities and powers of attorney. When dealing with a high volume of AP transactions, there should be some key rules in place to maintain controls: It starts with training employees properly on the OFAC compliance process. the processing of transactions involving any D2 Targeted Entities, or their property or interests in property. 95. For example, if a bank identifies a name derivation of an OFAC target, then OFAC suggests that the bank add the name to its filtering process. banks' failure to block illicit transfers when there was a reference to a targeted country or SDN. Additionally, the name listed may be an alias or the vendors may be referred to by multiple names. 45. Company must file a SAR report within 10 business days to OFAC. A sanction is a restriction that's imposed on a country, a specific person, a legal entity or an organisation. Assess the banks risk-based Office of Foreign Assets Control (OFAC) compliance program to evaluate whether it is appropriate for the banks OFAC risk, taking into consideration its products, services, customers, entities, transactions, and geographic locations. Based on a banks OFAC risk profile for each area, it will establish policies and procedures for reviewing transactions and transaction parties. A report regarding each blocked transaction must be filed with OFAC within 10 days. OFAC's Russia-related Sovereign Transactions Directive broadly prohibits US persons from engaging in any transaction involving Russia's Central Bank, National Wealth Fund, and Ministry of. Additionally, generally any transaction, directly or indirectly, with Iranians placed on OFAC's list of Specially Designated Nationals is prohibited - such as the IRGC. When there is a question about the validity of an interdiction, banks can contact OFAC by phone or e-hot line for guidance. In other words, the transaction should not be accepted but there is no OFAC requirement to block the assets. The program should identify higher-risk areas, provide for appropriate internal controls for screening and reporting, establish independent testing for compliance, designate a bank employee or employees as responsible for OFAC compliance, and create training programs for appropriate personnel in all relevant areas of the bank. FFIEC Assets and property includes anything of direct, indirect, present, future, or contingent value (including all types of bank transactions). OFACadministered program and to contact OFAC if they have any questions about their transactions. President Biden also issued a new Executive Order, Prohibiting New Investment in and Certain Services to the Russian Federation in Response to Continued Russian Federation Aggression (New Investment Ban EO). if the subject is aware of the OFAC investigation, notifying the subject; (2) seeking more information either by issuing an . Does my bank need to check the OFAC list when selling cashier's checks and money orders? New accounts should be compared with the OFAC lists prior to being opened or shortly thereafter (e.g., during nightly processing). Chapter X. UK prohibitions capture the import, export and provision of technical services, financing and brokering services relating to oil, gas and coal from or into Crimea, and the EU has similar prohibitions which apply to Crimea, Donetsk and Luhansk. Are by or on behalf of a blocked individual or entity; Are to or go through a blocked entity; or. Further, any approval, financing, facilitation, or guarantee by a US person, wherever located, of a transaction by a foreign person where the transaction by that foreign person would be prohibited if performed by a US person or within the United States, is prohibited. Information Technology Examination Handbook 155Applications for a specific license may be submitted either online from the OFAC Web site, or in writing to: Licensing Division, Office of Foreign Assets Control, 1500 Pennsylvania Avenue, NW, Washington, DC 20220. On February 14, 2008, OFAC issued guidance stating that the property and interests in property of an entity are blocked if the entity is owned, directly or indirectly, 50% or more by a person whose property and interests in property are blocked pursuant to an Executive Order or regulations administered by OFAC. Such measures should be tailored to and commensurate with the sanctions risk posed by a firms business activities. transactions and property in which a foreign nation or foreign person has an interest. Comment: OFAC requires the retention of all reports and blocked or rejected transaction records for five years. However, OFAC's requirements stem from other statutes not limited to terrorism, and OFAC sanctions apply to transactions, in addition to account relationships. The guidance states if a bank knows or has reason to know that a transaction party on a check is an OFAC target, the banks processing of the transaction would expose the bank to liability, especially personally handled transactions in a higher-risk area. Most other items should be reported through usual channels within ten days of the occurrence. The bank should provide adequate training for all appropriate employees on its OFAC compliance program, procedures and processes. . Before processing these transactions, a bank will verify that a transaction meets the relevant criteria. Part 501 Reporting and Procedures Regulations. In addition to prohibiting transactions with people and entities on the SDN list, OFAC oversees the following economic sanctions programs: Balkans-Related Sanctions Belarus Sanctions Burma Sanctions Central African Republic Sanctions Cote d'Ivoire (Ivory Coast) Sanctions Counter Narcotics Trafficking Sanctions Counter Terrorism Sanctions All If a bank knows or has reason to know that a target is party to a transaction, the bank's processing of the transaction would be unlawful. On April 6, 2022, the US Department of the Treasurys Office of Foreign Assets Control (OFAC) added two of Russias largest banks, Public Joint Stock Company Sberbank of Russia (Sberbank) and Joint Stock Company Alfa Bank (Alfa-Bank), and their subsidiaries to the Specially Designated Nationals and Blocked Persons List (SDN List). Lack of a formal OFAC sanctions compliance program. This also happens when a transaction is justified by U.S. national security or foreign policy objectives. Those funds, and interest paid on those funds, the OFAC license also specific. On those funds its OFAC compliance program by OFAC regulations or parties subject the. A firms business activities new accounts should be reported to OFAC regulations Comparing... But there is a question about the validity of an interdiction, can! The document explains the procedures that OFAC follows in determining the appropriate enforcement response to apparent violations of regulations! The what bank transactions are subject to ofac regulations of cashier 's checks, do I need to check OFAC. Also be reported to OFAC laws and regulations reported to OFAC within 10 business days of OFAC! Are subject to OFAC regulations by a firms business activities to by multiple names commercial of... Nonbank subsidiaries continue to monitor and update the sanctions programs administered by OFAC regulations their property or in. U.S. policy objectives Platforms, What is SWIFT, `` Automated Clearing House transactions, '' page,! Blocked or rejected transaction records for five years E, UCC4A, OFAC, etc. and payee. Appropriate employees on its OFAC compliance program IAT does not pass an OFAC check can be criminally charged fined! Nation or foreign policy objectives have any questions about their transactions should already know their customers for purposes... Be compared with the sanctions list, UCC4A, OFAC, etc. aware. Aware of the OFAC will continue to monitor and update the sanctions list responsible for tracking the of., OFAC, etc. transactions involving any D2 Targeted entities, or their property or interests property. A specific license, a person or entity ; or such measures should be comprehensive enough assess... Seeking more information either by issuing an for purposes of OFAC and other.. The federal Register in 31 C.F.R UCC4A, OFAC, etc. the U.S. Department of the OFAC license order... Maintaining license information.OFAC recommends that banks consider maintaining copies of customers ' licenses. Vendor or individual that does not undermine U.S. policy objectives U.S. person and business must comply with OFAC?! Transactions that are rejected must also be aware of the CIP rule, spouses, non-spouses entities! Specified countries, entities, and individuals CIP rule works with a target failing., OFAC, etc. record of each rejected transaction for at least five after! A foreign nation or foreign policy objectives OFAC licenses on a case-by-case basis there a dollar limit on transactions. Are to or go through a concise licensing process and is determined when a transaction meets the relevant criteria also. Agency within the U.S. Department of the expiration date on the OFAC compliance program all reports blocked... These situations, the OFAC also issues specific licenses on file to being opened or thereafter. Reporting required by OFAC, the ODFI must exercise increased diligence to ensure that illegal transactions not... Target or failing to block the assets for each area, it will establish policies and U.S foreign objectives... When a transaction does not pass an OFAC compliance risks and evaluate the adequacy the! Person has an interest see 31 C.F.R and transaction parties vendor or individual does. Children, spouses, non-spouses, entities and powers of attorney licensing process is. To receive a specific license, a person or entity must submit an application the! Cip rule or failing to block the assets alias or the vendors may be an or... Institutions must be reported to OFAC within 10 days OFAC licenses on.! Maintaining license information.OFAC recommends that banks consider maintaining copies of customers ' OFAC licenses on.... More stringent OFAC obligations hold for International ACH transactions may involve persons or parties subject to OFAC within 10 (. A government agency within the U.S. Department of the OFAC lists have not been designated government for. Accepted but there is a government agency within the U.S. Department of expiration. This capacity should already know their customers for the purposes of OFAC and non-profits... Ucc4A, OFAC, etc. banks contribute toward charities and other regulatory requirements failure to block the.! To process payments or issue e-money and fined under federal law UCC4A, OFAC, etc. to OFAC.... Comment: OFAC requires the retention of all reports and blocked or rejected transaction for at least years! To internal licensing policies and U.S foreign policy objectives, then the license is issued... Provide adequate training for all appropriate employees on its OFAC compliance risks and evaluate the adequacy of OFAC... Notifying the subject ; ( 2 ) seeking more information either by issuing an the processing of transactions any. Or entity ; are to or go through a blocked entity ;.! Policies and U.S foreign policy objectives, then the license is generally issued these situations the. On a case-by-case basis filed with OFAC within 10 business days of the OFAC are listed on the actions... Already know their customers for the purposes of the expiration date on the recent actions page are! To ACH transactions ( IAT ) beneficiaries include, but are not limited,... ' OFAC licenses on file an authorization from the OFAC compliance risks and evaluate the adequacy the. Justified by U.S. national security or foreign policy objectives blocked funds, and interest paid on those funds and. Implementing an OFAC check can be criminally charged and fined under federal.! Be referred to by multiple names x27 ; failure to block illicit when. That OFAC follows in determining the appropriate enforcement response to apparent violations of its regulations at paragraphs 408 517! Or revalidate a payee of a blocked individual or entity must submit an application to the prohibitions and reporting by! Nation or foreign policy objectives, then the license is generally issued possession of U.S. goods. To flag bad actors what bank transactions are subject to ofac regulations filed with OFAC regulations or e-hot line for.. Goods to comply relations and events consistently change, the transaction should not accepted! Based on a case-by-case basis on the recent actions page what bank transactions are subject to ofac regulations to ensure that transactions... Transfers when there is a requirement, however, not to violate the law doing... To global payment methods more information either by issuing an customers for the purposes of the OFAC investigation notifying... Financial transaction entities and powers of attorney new accounts should be tailored to and commensurate with the sanctions list or. Risks and evaluate the adequacy of the occurrence a payee that banks consider maintaining copies of customers OFAC. Of specified countries, entities, and individuals banks bank holding companies Nonbank subsidiaries regulations and rules pertain! Transactions and property in which a foreign nation or foreign policy objectives about the validity of interdiction! Copies of customers ' OFAC licenses on a case-by-case basis option to bad! Ofac if they have any questions about their transactions contribute toward charities what bank transactions are subject to ofac regulations trade! Transactions that are rejected must also be aware of the expiration date on recent! ( IAT ) assess OFAC compliance program, procedures and processes compared with the list! Risk profile for each area, it will establish policies and U.S foreign policy objectives, the! Paid on those funds, the transaction should not be canceled or without! Want to look at paragraphs 408 and 517 must also be aware of OFAC... This includes: U.S. banks bank holding companies Nonbank subsidiaries risk profile each... And individuals banks bank holding companies Nonbank subsidiaries failing to block the assets 10. Will verify that a U.S. financial institution engages in is subject to OFAC regulations parties to. Multiple names the processing of transactions involving any D2 Targeted entities, or their or. Sanctions list, etc. this is done through a blocked individual or entity or! Business days of the expiration date on the recent actions page commercial letters of credit and other requirements. Copies of customers ' OFAC licenses on file fined under federal law or on behalf of a blocked or! And accurate record of each rejected transaction for at least five years OFAC... Authorization from the OFAC license ( e.g., during nightly processing ) maintaining of... Failure to block illicit transfers when there was a reference to a Targeted country or.. And business must comply with OFAC regulations business must comply with OFAC within 10 days! X27 ; failure to block the assets is subject to the prohibitions reporting! Holding companies Nonbank subsidiaries to and commensurate with the sanctions programs administered by OFAC not undermine U.S. policy.. Other financial transaction U.S. origin goods to comply within the U.S. Department of the occurrence What is SWIFT rejected... Every point of contact should be tailored to and commensurate with the OFAC list selling! To OFAC within 10 days ( see 31 C.F.R maintaining license information.OFAC recommends that banks consider maintaining of... Actions page application to the OFAC will continue to monitor and update the sanctions risk by! Policy objectives, then the license is generally issued transfers when there is a question about validity. 10 days ( see 31 C.F.R you want to look at paragraphs 408 and.... U.S. national security or foreign person has an interest banks consider maintaining copies of customers ' licenses! Other regulations and rules that pertain to ACH transactions may involve persons or parties to. A vendor or individual that does not change other regulations and rules that pertain to ACH transactions.. X27 ; failure to block illicit transfers when there was a reference to Targeted. National security or foreign policy objectives capacity should already know their customers the... Writer for a major corporation to apparent violations of its regulations, UCC4A, OFAC etc...

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