Gulf International Bank (UK) Limited

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F.
or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If
an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or
applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory
affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only
if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that
occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or
CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
OFFICE OF FOREIGN ASSETS CONTROL, US DEPARTMENT OF THE TREASURY (OFAC)
2.
Principal Sanction:

Other
Other Sanctions: 
NO SANCTIONS HAVE BEEN ASSESSED AS OF THE DATE OF THIS FILING. GIB (UK) IS COMPLETING THIS REPORTING PAGE AS A RESULT OF A PENDING PROCEEDING
WITH OFAC. THERE HAVE BEEN NO FORMAL COMMUNICATIONS WITH OFAC SINCE THE DATE OF GIB(UK)'S LAST ANNUAL UPDATE TO FORM ADV. AS AT THE DATE OF
THIS REPORT THE APPLICATION HAS BEEN DENIED.
3.
Date Initiated (MM/DD/YYYY): 
05/23/2014
 Exact
 Explanation
If not exact, provide explanation:
THE DATE PROVIDED IS THE DATE OF GIB UK'S WRITTEN SELF-REPORT TO OFAC.
4.
Docket/Case Number:
IA-2013-306322-1
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
THE PENDING PROCEEDING WITH OFAC RELATES TO CERTAIN TRANSFERS OF FUNDS DENOMINATED IN US DOLLARS.
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
GIB(UK) WAS INSTRUCTED BY A NON-US CLIENT TO MAKE FIVE PAYMENTS IN US DOLLARS (US$124, 000 IN TOTAL) TO AN ACCOUNT IN TURKEY HELD BY A MULTI-
JURISDICTIONAL ENTITY. GIB(UK) WAS NOT AWARE AT THE TIME THESE PAYMENTS WERE MADE THAT THE ENTITY WAS HEADQUARTERED IN IRAN. PAYMENT
INSTRUCTIONS GAVE NO INDICATION OF HEADQUARTER DOMICILE AND GIB(UK)'S SANCTION CHECKING PROCESS DID NOT IDENTIFY THE LINK TO IRAN. THE
TRANSACTIONS WERE EFFECTED THROUGH GIB(UK)'S CORRESPONDENT BANK, THE LAST OF WHICH WAS BLOCKED IN NOVEMBER 2013. FOLLOWING NOTIFICATION
OF THE LINK TO IRAN BY THE CORRESPONDENT BANK, GIB(UK) APPLIED TO OFAC FOR UNBLOCKING OF THE LAST TRANSACTION IN DECEMBER 2013. IN MAY 2014,
GIB(UK) SELF-REPORTED THE TRANSACTIONS TO OFAC PURSUANT TO OFAC'S ENFORCEMENT GUIDELINES FOR ECONOMIC SANCTIONS (31 C.F.R. PART 501,
APPENDIX A). AS AT THE DATE OF THIS REPORT THE APPLICATION HAS BEEN DENIED.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
11. Resolution Date (MM/DD/YYYY):
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial
Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of
exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation,
provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within
the space provided).
GIB(UK) WAS INSTRUCTED BY A NON-US CLIENT TO MAKE FIVE PAYMENTS IN US DOLLARS (US$124, 000 IN TOTAL) TO AN ACCOUNT IN TURKEY HELD BY A MULTI-
JURISDICTIONAL ENTITY. GIB(UK) WAS NOT AWARE AT THE TIME THESE PAYMENTS WERE MADE THAT THE ENTITY WAS HEADQUARTERED IN IRAN. PAYMENT
INSTRUCTIONS GAVE NO INDICATION OF HEADQUARTER DOMICILE AND GIB(UK)'S SANCTION CHECKING PROCESS DID NOT IDENTIFY THE LINK TO IRAN. THE
TRANSACTIONS WERE EFFECTED THROUGH GIB(UK)'S CORRESPONDENT BANK, THE LAST OF WHICH WAS BLOCKED IN NOVEMBER 2013. FOLLOWING NOTIFICATION
OF THE LINK TO IRAN BY THE CORRESPONDENT BANK, GIB(UK) APPLIED TO OFAC FOR UNBLOCKING OF THE LAST TRANSACTION IN DECEMBER 2013. IN MAY 2014,
GIB(UK) SELF-REPORTED THE TRANSACTIONS TO OFAC PURSUANT TO OFAC'S ENFORCEMENT GUIDELINES FOR ECONOMIC SANCTIONS (31 C.F.R. PART 501,
APPENDIX A). AS AT THE DATE OF THIS REPORT THE APPLICATION HAS BEEN DENIED.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F.
or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If
an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or
applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory
affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only
if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that
occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or
CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
OFFICE OF FOREIGN ASSETS CONTROL, US DEPARTMENT OF THE TREASURY (OFAC)
2.
Principal Sanction:
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
11/18/2022
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:

RUSSIA-EO14024-2022-1004859-1
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
THE PENDING PROCEEDING WITH OFAC RELATES TO CERTAIN TRANSFERS OF FUNDS DENOMINATED IN US DOLLARS.
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
OUR NON-US CLIENT INSTRUCTED US TO MAKE A PAYMENT TO AN INDIVIDUAL IN AFGHANISTAN AS PART OF THEIR SCHOLARSHIP PROGRAM FOR US$927.50 FOR
VALUE 3 AUGUST. WITHIN THEIR PAYMENT INSTRUCTION WAS INCLUDED AN INTERMEDIARY BANK, CITIBANK AND AN ACCOUNT NUMBER 36313578. GIB(UK) MADE
THE PAYMENT AS INSTRUCTED BY OUR CLIENT VIA OUR CORRESPONDENT BANK ACCOUNT WITH JP MORGAN. SOME TIME LATER JPMORGAN NOTIFIED US THAT THE
FUNDS WERE BLOCKED AND REPORTED TO OFAC. IT WAS THEN UNDERSTOOD THAT THE ACCOUNT NUMBER AT CITIBANK THAT WAS QUOTED IN THE PAYMENT
INSTRUCTION BELONGED TO TRANSKAPITALBANK, A RUSSIAN BANK THAT WAS SUBJECT TO SANCTIONS. GIB(UK) WAS SUBSEQUENTLY NOTIFIED THAT THIS
PAYMENT HAD BEEN BLOCKED AND REPORTED TO OFAC PURSUANT TO THE RUSSIAN SANCTIONS REGULATIONS. GIB(UK) APPLIED TO OFAC FOR A LICENCE TO
EFFECT THIS PAYMENT. ON 19 SEPTEMBER 2025, JP MORGAN RETURNED THE PAYMENT TO GIB(UK) WITH INTEREST AND WE HAVE RETURNED IT TO OUR CLIENT.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
11. Resolution Date (MM/DD/YYYY):
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial
Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of
exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation,
provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within
the space provided).
OUR NON-US CLIENT INSTRUCTED US TO MAKE A PAYMENT TO AN INDIVIDUAL IN AFGHANISTAN AS PART OF THEIR SCHOLARSHIP PROGRAM FOR US$927.50 FOR
VALUE 3 AUGUST. WITHIN THEIR PAYMENT INSTRUCTION WAS INCLUDED AN INTERMEDIARY BANK, CITIBANK AND AN ACCOUNT NUMBER 36313578. GIB(UK) MADE
THE PAYMENT AS INSTRUCTED BY OUR CLIENT VIA OUR CORRESPONDENT BANK ACCOUNT WITH JP MORGAN. SOME TIME LATER JPMORGAN NOTIFIED US THAT THE
FUNDS WERE BLOCKED AND REPORTED TO OFAC. IT WAS THEN UNDERSTOOD THAT THE ACCOUNT NUMBER AT CITIBANK THAT WAS QUOTED IN THE PAYMENT
INSTRUCTION BELONGED TO TRANSKAPITALBANK, A RUSSIAN BANK THAT WAS SUBJECT TO SANCTIONS. GIB(UK) WAS SUBSEQUENTLY NOTIFIED THAT THIS
PAYMENT HAD BEEN BLOCKED AND REPORTED TO OFAC PURSUANT TO THE RUSSIAN SANCTIONS REGULATIONS. GIB(UK) APPLIED TO OFAC FOR A LICENCE TO
EFFECT THIS PAYMENT. ON 19 SEPTEMBER 2025, JP MORGAN RETURNED THE PAYMENT TO GIB(UK) WITH INTEREST AND WE HAVE RETURNED IT TO OUR CLIENT.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F.
or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)

11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If
an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or
applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory
affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only
if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that
occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or
CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
OFFICE OF FOREIGN ASSETS CONTROL, US DEPARTMENT OF THE TREASURY (OFAC)
2.
Principal Sanction:
Other
Other Sanctions: 
NO SANCTIONS HAVE BEEN ASSESSED AS OF THE DATE OF THIS FILING. GIB (UK) IS COMPLETING THIS REPORTING PAGE AS A RESULT OF A PENDING PROCEEDING
WITH OFAC.
3.
Date Initiated (MM/DD/YYYY): 
01/18/2023
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
RUSSIA-EO14024-2023-1032862-1
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
THE PENDING PROCEEDING WITH OFAC RELATES TO CERTAIN TRANSFERS OF FUNDS DENOMINATED IN US DOLLARS.
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):

A PAYMENT INSTRUCTION WAS RECEIVED FROM OUR NON-US CLIENT TO PAY A SALARY TO AN INDIVIDUAL IN KYRGYZSTAN AT A LOCAL BANK, VALUE USD5638.64.
WHEN PROCESSING THIS TRANSACTION WE SELECTED SBERBANK AS THEIR CORRESPONDENT BANK TO EFFECT USD PAYMENTS. WE WERE LATER NOTIFIED BY
HSBC, OUR USD CORRESPONDENT BANK THAT THEY HAD FROZEN THE PAYMENT AND REPORTED IT TO OFAC DUE TO THE SANCTIONS BREACH. WE HAVE APPLIED TO
OFAC FOR A LICENCE TO EFFECT THIS PAYMENT, WHICH IS CURRENTLY PENDING WITH THEM.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
11. Resolution Date (MM/DD/YYYY):
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial
Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of
exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation,
provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within
the space provided).
A PAYMENT INSTRUCTION WAS RECEIVED FROM OUR NON-US CLIENT TO PAY A SALARY TO AN INDIVIDUAL IN KYRGYZSTAN AT A LOCAL BANK, VALUE USD5638.64.
WHEN PROCESSING THIS TRANSACTION WE SELECTED SBERBANK AS THEIR CORRESPONDENT BANK TO EFFECT USD PAYMENTS. WE WERE LATER NOTIFIED BY
HSBC, OUR USD CORRESPONDENT BANK THAT THEY HAD FROZEN THE PAYMENT AND REPORTED IT TO OFAC DUE TO THE SANCTIONS BREACH. WE HAVE APPLIED TO
OFAC FOR A LICENCE TO EFFECT THIS PAYMENT, WHICH IS CURRENTLY PENDING WITH THEM.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F.
or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If
an event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates

If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
No Information Filed
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or
applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory
affiliate's favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only
if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that
occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or
CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
OFFICE OF FOREIGN ASSETS CONTROL, US DEPARTMENT OF THE TREASURY (OFAC)
2.
Principal Sanction:
Other
Other Sanctions: 
NO SANCTIONS HAVE BEEN ASSESSED AS OF THE DATE OF THIS FILING. GIB (UK) IS COMPLETING THIS REPORTING PAGE AS A RESULT OF A PENDING PROCEEDING
WITH OFAC.
3.
Date Initiated (MM/DD/YYYY): 
12/12/2024
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
THE PENDING PROCEEDING WITH OFAC RELATES TO CERTAIN TRANSFERS OF FUNDS DENOMINATED IN US DOLLARS
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
IN DECEMBER 2024, JP MORGAN, OUR US$ CORRESPONDENT BANK, BLOCKED AND REPORTED TO OFAC A PAYMENT TO AN INDIVIDUAL OF USD2,200 DUE TO A
SUPPOSED BREACH OF IRANIAN SANCTIONS REGULATIONS. OUR INTERNAL INVESTIGATIONS HAVE CONCLUDED THAT THERE WAS NO SANCTIONS BREACH. THIS
PAYMENT WENT DIRECTLY TO A NIGERIAN INDIVIDUAL WHO IS STUDYING IN MALAYSIA, WHOSE BANK ACCOUNT IS HELD WITH A LARGE KUWAITI BANK, SO IT WAS
CLEAR TO US THAT THERE WAS NO NEXUS TO IRAN. WE HAVE ALSO OBTAINED THE BENEFICIARY'S PASSPORT TO VERIFY THE INFORMATION. WE HAVE EXPLAINED
OUR FINDINGS AND RATIONALE TO JP MORGAN, WHICH HAS STOOD BY ITS DECISION. GIB(UK) APPLIED TO OFAC FOR A LICENSE TO HAVE THE FUNDS UNBLOCKED
WITH NO UPDATES FROM OFAC SO FAR.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:

11. Resolution Date (MM/DD/YYYY):
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial
Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of
exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation,
provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: 
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within
the space provided).
IN DECEMBER 2024, JP MORGAN, OUR US$ CORRESPONDENT BANK, BLOCKED AND REPORTED TO OFAC A PAYMENT TO AN INDIVIDUAL OF USD2,200 DUE TO A
SUPPOSED BREACH OF IRANIAN SANCTIONS REGULATIONS. OUR INTERNAL INVESTIGATIONS HAVE CONCLUDED THAT THERE WAS NO SANCTIONS BREACH. THIS
PAYMENT WENT DIRECTLY TO A NIGERIAN INDIVIDUAL WHO IS STUDYING IN MALAYSIA, WHOSE BANK ACCOUNT IS HELD WITH A LARGE KUWAITI BANK, SO IT WAS
CLEAR TO US THAT THERE WAS NO NEXUS TO IRAN. WE HAVE ALSO OBTAINED THE BENEFICIARY'S PASSPORT TO VERIFY THE INFORMATION. WE HAVE EXPLAINED
OUR FINDINGS AND RATIONALE TO JP MORGAN, WHICH HAS STOOD BY ITS DECISION. GIB(UK) APPLIED TO OFAC FOR A LICENSE TO HAVE THE FUNDS UNBLOCKED
WITH NO UPDATES FROM OFAC SO FAR.