GLDUS130 Aspen Grove Capital, LLC
(A) named on any prohibited lists maintained by the U.S- or UK government,
including, but not limited to, the OFAC list of Specially Designated
Nationals ... subject of an advisory issued by the Financial Crimes
Enforcement Network of the U.S- Treasury• Department; or (iii) has been
designated by the Secretary of the Treasury• under Section
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01393439.pdf