Common use of AML Compliance Clause in Contracts

AML Compliance. FTIS shall comply with the Investment Company’s and FTIS’ policies and procedures to: implement the Investment Company’s Anti-Money Laundering (“AML”), Customer Identification (“CIP”) Programs and any applicable identity theft regulatory requirements (the “Red Flags Rules”), as such policies and procedures may be amended from time to time, including currency transaction reporting; screen account names and addresses against the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) list of Specially Designated Nationals and Blocked Persons (the “SDN list”) and the country-based U.S. trade and economic sanctions programs administered by OFAC; respond to requests for information from the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) pursuant to Section 314(a) of the USA PATRIOT Act; file Suspicious Activity Reports (“SARs”), as necessary, on behalf of the Investment Company; and perform such other anti-money laundering functions as agent of the Investment Company.

AML Compliance. FTIS shall comply with the Investment Company’s and FTIS’ policies and procedures to: implement the Investment Company’s Anti-Money Laundering (“AML”), Customer Identification (“CIP”) Programs and any applicable identity theft regulatory requirements (the “Red Flags Rules”), as such policies and procedures may be amended from time to time, including currency transaction reporting; screen account names and addresses against the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) list of Specially Designated Nationals and Blocked Persons (the “SDN list”) and the country-country- based U.S. trade and economic sanctions programs administered by OFAC; respond to requests for information from the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) pursuant to Section 314(a) of the USA PATRIOT Act; file Suspicious Activity Reports (“SARs”), as necessary, on behalf of the Investment Company; and perform such other anti-money laundering functions as agent of the Investment Company.