Sanctions Program. The Authorized Participant represents, covenants and warrants that it, and any Agent, and shall require appropriate representations and perform appropriate diligence reasonably designed to ensure that such Authorized Participant Client, has adopted, implemented, and shall maintain and comply with a reasonable risk-based program to comply with all applicable economic, trade and financial sanctions laws, resolutions, executive orders and regulations enacted by the United States (including as administered and/or enforced by the Office of Foreign Assets Control), the United Kingdom, United Nations, European Union, and any applicable sanctions authority (collectively, “Sanctions Laws”). The Authorized Participant represents, covenants and warrants that it and any Agent shall maintain and comply, and shall require appropriate representations from and perform appropriate diligence on any Authorized Participant Client reasonably designed to ensure that such Authorized Participant Client shall maintain and comply, with policies, procedures and controls that are reasonably designed to ensure (i) compliance with Sanctions Laws and limit the risk of transactions that could be regarded as circumventing Sanctions Laws and (ii) that it, its affiliates, or its Agents or any Authorized Participant Client, and, to the extent required by law, its and their owners and controllers (a) are not in violation of any Sanctions Laws or on any list of prohibited individuals or entities enacted under Sanctions Laws (collectively, “Sanctions Lists”) and (b) are not located, organized or doing business in a country or territory that is, or whose government is, the target of embargo or countrywide sanctions under any Sanctions Laws. The Authorized Participant represents, covenants, and warrants that (i) it shall require appropriate representations from, and perform appropriate diligence on, any Authorized Participant Client designed to ensure that the Authorized Participant Client shall take reasonable steps to ensure that any Delivery of bitcoin to the Trust performed by the Authorized Participant Client; and (ii) any Delivery of bitcoin to the Trust performed by the Authorized Participant or its Agent; in each case, shall not be directly or indirectly derived from, invested for the benefit of or related in any way to, persons, entities or jurisdictions that are subject to any country embargoes, in violation of any Sanctions Laws or on any Sanctions Lists. The Authorized Participant con...
Sanctions Program. The Authorized Participant represents, covenants and warrants solely to the Sponsor that it has established and presently maintains: (1) policies, procedures and controls designed to comply with applicable anti-money laundering laws; and (2) a sanctions program (the “Sanctions Program”) reasonably designed to prevent it from engaging in activities, financial transactions or other illicit purposes for or on behalf of individuals or entities in line with applicable sanctions laws and regulations, and it shall comply with the Sanctions Program and all applicable sanctions laws, regulations and rules now or hereafter in effect. The Authorized Participant acknowledges that the Digital Asset Custodian and the Cash Custodian may reject any deposit property which is subject to applicable sanctions and anti-money laundering laws. The Authorized Participant represents that it will not cause the Fund to hold any ether or other Digital Asset that originates from a financial crime or that is being or has been used to facilitate the violation of any sanctions or anti-money laundering laws.
Sanctions Program. The Authorized Participant represents, covenants and warrants solely to the Sponsor that it has established and presently maintains a sanctions program (the “Sanctions Program”) reasonably designed to prevent it from engaging in activities, financial transactions or other illicit purposes for or on behalf of individuals or entities in line with applicable sanctions laws and regulations, and it shall comply with the Sanctions Program and all applicable sanctions laws, regulations and rules now or hereafter in effect. The Authorized Participant acknowledges that that the Custodian may reject any Deposit Property which is subject to applicable sanctions, including without limitation OFAC sanctioned brands.
Sanctions Program. The Authorized Participant represents, covenants and warrants solely to the Sponsor that it has established and presently maintains a sanctions program (the “Sanctions Program”) reasonably designed to prevent it from engaging in activities, financial transactions or other illicit purposes for or on behalf of individuals or entities in line with applicable sanctions laws and regulations, and it shall comply with the Sanctions Program and all applicable sanctions laws, regulations and rules now or hereafter in effect. The Authorized Participant acknowledges that that the Custodian may reject any deposit property which is subject to applicable sanctions, including without limitation OFAC sanctioned brands. The Authorized Participant represents that it will not cause the Fund to hold any Gold that originates from a financial crime or that is being or has been used to facilitate the violation of any sanctions.
