Common use of AML Compliance Clause in Contracts

AML Compliance. As part of the AML program, the AMLO shall, among other things: a) Assist the Trust in identifying its AML vulnerabilities and identify the risk factors relating to the AML requirements; b) Review the adequacy of the Trust’s AML program and the effectiveness of its implementation and, as necessary, make recommendations regarding updating the Trust’s AML program to accommodate changes in regulatory requirements and the Trust’s business; c) Provide ongoing AML training for appropriate persons; d) Perform testing of certain control procedures, including collecting and organizing relevant data and reviewing reports, investigating exceptions, and making inquiries of Trust personnel and relevant Service Providers; e) Arrange for independent testing of the Funds’ AML programs; f) Monitor and review AML responsibilities that have been delegated to Service Providers; g) Conduct on-site visits of appropriate Service Providers as necessary; h) Oversee (to the extent not delegated to Service Providers) suspicious activity reporting (on form SAR-SF); i) Assist Trust personnel in responding to Section 314(a) information requests; and

AML Compliance. As part of the AML program, the AMLO shall, among other things: a) Assist the Trust Fund in identifying its AML vulnerabilities and identify the risk factors relating to the AML requirements; b) Review the adequacy of the TrustFund’s AML program and the effectiveness of its implementation and, as necessary, make recommendations regarding updating the TrustFund’s AML program to accommodate changes in regulatory requirements and the TrustFund’s business; c) Provide ongoing AML training for appropriate persons; d) Perform testing of certain control procedures, including collecting and organizing relevant data and reviewing reports, investigating exceptions, and making inquiries of Trust Fund personnel and relevant Service Providers; e) Arrange for independent testing of the Funds’ Fund’s AML programs; f) Monitor and review AML responsibilities that have been delegated to Service Providers; g) Conduct on-site visits of appropriate Service Providers as necessary; h) Oversee (to the extent not delegated to Service Providers) suspicious activity reporting (on form SAR-SF); i) Assist Trust Fund personnel in responding to Section 314(a) information requests; and

AML Compliance. As part of the AML program, the AMLO shall, among other things: a) Assist the Trust in identifying its AML vulnerabilities and identify the risk factors relating to the AML requirements; b) Review the adequacy of the Trust’s AML program and the effectiveness of its implementation and, as necessary, make recommendations regarding updating the Trust’s AML program to accommodate changes in regulatory requirements and the Trust’s business; c) Provide ongoing AML training for appropriate persons; d) Perform testing of certain control procedures, including collecting and organizing relevant data and reviewing reports, investigating exceptions, and making inquiries of the Trust personnel and relevant Service Providers; e) Arrange for independent testing of the Funds’ Trust’s AML programs; f) Monitor and review AML responsibilities that have been delegated to Service Providers; g) Conduct on-site visits of appropriate Service Providers as necessary; h) Oversee (to the extent not delegated to Service Providers) suspicious activity reporting (on form SAR-SF); i) Assist Trust the Trust’s personnel in responding to Section 314(a) information requests; and

AML Compliance. As part of the AML program, the AMLO shall, among other things: a) Assist the Trust Company in identifying its AML vulnerabilities and identify the risk factors relating to the AML requirements; b) Review the adequacy of the TrustCompany’s AML program and the effectiveness of its implementation and, as necessary, make recommendations regarding updating the TrustCompany’s AML program to accommodate changes in regulatory requirements and the TrustCompany’s business; c) Provide ongoing AML training for appropriate persons; d) Perform testing of certain control procedures, including collecting and organizing relevant data and reviewing reports, investigating exceptions, and making inquiries of Trust Company personnel and relevant Service Providers; e) Arrange for independent testing of the Funds’ AML programs; f) Monitor and review AML responsibilities that have been delegated to Service Providers; g) Conduct on-site visits of appropriate Service Providers as necessary; h) Oversee (to the extent not delegated to Service Providers) suspicious activity reporting (on form SAR-SF); i) Assist Trust Company personnel in responding to Section 314(a) information requests; and

AML Compliance. As part of the AML program, the AMLO shall, among other things: a) Assist the Trust Client in identifying its AML vulnerabilities and identify the risk factors relating to the AML requirements; b) Review the adequacy of the TrustClient’s AML program and the effectiveness of its implementation and, as necessary, make recommendations regarding updating the TrustClient’s AML program to accommodate changes in regulatory requirements and the TrustClient’s business; c) Provide ongoing AML training for appropriate persons; d) Perform testing of certain control procedures, including collecting and organizing relevant data and reviewing reports, investigating exceptions, and making inquiries of Trust Client personnel and relevant Service Providers; e) Arrange for independent testing of the Funds’ AML programs; f) Monitor and review AML responsibilities that have been delegated to Service Providers; g) Conduct on-site visits of appropriate Service Providers as necessary; h) Oversee (to the extent not delegated to Service Providers) suspicious activity reporting (on form SAR-SF); i) Assist Trust Client personnel in responding to Section 314(a314( a) information requests; and

AML Compliance. As part of the AML program, the AMLO shall, among other things: a) Assist the Trust in identifying its AML vulnerabilities and identify the risk factors relating to the AML requirements; b) Review the adequacy of the Trust’s AML program and the effectiveness of its implementation and, as necessary, make recommendations regarding updating the Trust’s AML program to accommodate changes in regulatory requirements and the Trust’s business; c) Provide ongoing AML training for appropriate persons; d) Perform testing of certain control procedures, including collecting and organizing relevant data and reviewing reports, investigating exceptions, and making inquiries of Trust personnel and relevant Service Providers; e) Arrange for independent testing of the Funds’ AML programs; f) Monitor and review AML responsibilities that have been delegated to Service Providers; g) Conduct on-site visits of appropriate Service Providers as necessary; h) Oversee (to the extent not delegated to Service Providers) suspicious activity reporting (on form SAR-SF); i) Assist Trust personnel in responding to Section 314(a3l 4(a) information requests; and

AML Compliance. As part of the AML program, the AMLO shall, among other things: a) Assist the Trust Client in identifying its AML vulnerabilities and identify the risk factors relating to the AML requirements; b) Review the adequacy of the TrustClient’s AML program and the effectiveness of its implementation and, as necessary, make recommendations regarding updating the TrustClient’s AML program to accommodate changes in regulatory requirements and the TrustClient’s business; c) Provide ongoing AML training for appropriate persons; d) Perform testing of certain control procedures, including collecting and organizing relevant data and reviewing reports, investigating investigating, exceptions, and making inquiries of Trust Client personnel and relevant Service Providers; e) Arrange for independent testing of the Funds’ AML programs; f) Monitor and review AML responsibilities that have been delegated to Service Providers; g) Conduct on-site visits of appropriate Service Providers as necessary; h) Oversee (to the extent not delegated to Service Providers) suspicious activity reporting (on form SAR-SF); i) Assist Trust Client personnel in responding to Section 314(a) information requests; and

AML Compliance. As part of the AML program, the AMLO shall, among other things: a) Assist the Trust Fund in identifying its AML vulnerabilities and identify the risk factors relating to the AML requirements; b) Review the adequacy of the TrustFund’s AML program and the effectiveness of its implementation and, as necessary, make recommendations regarding updating the TrustFund’s AML program to accommodate changes in regulatory requirements and the TrustFund’s business; c) Provide ongoing AML training for appropriate persons; d) Perform testing of certain control procedures, including collecting and organizing relevant data and reviewing reports, investigating exceptions, and making inquiries of Trust Fund personnel and relevant Service Providers; e) Arrange for independent testing of the Funds’ AML programs; f) Monitor and review AML responsibilities that have been delegated to Service Providers; g) Conduct on-site visits of appropriate Service Providers as necessary; h) Oversee (to the extent not delegated to Service Providers) suspicious activity reporting (on form SAR-SF); i) Assist Trust Fund personnel in responding to Section 314(a) information requests; and

AML Compliance. As part of the AML program, the AMLO shall, among other things: a) Assist the Trust Fund in identifying its AML vulnerabilities and identify the risk factors relating to the AML requirements; b) Review the adequacy of the TrustFund’s AML program and the effectiveness of its implementation and, as necessary, make recommendations regarding updating the TrustFund’s AML program to accommodate changes in regulatory requirements and the TrustFund’s business; c) Provide ongoing AML training for appropriate persons; d) Perform testing of certain control procedures, including collecting and organizing relevant data and reviewing reports, investigating exceptions, and making inquiries of Trust the Fund’s personnel and relevant Service Providers; e) Arrange for independent testing of the Funds’ Fund’s AML programs; f) Monitor and review AML responsibilities that have been delegated to Service Providers; g) Conduct on-site visits of appropriate Service Providers as necessary; h) Oversee (to the extent not delegated to Service Providers) suspicious activity reporting (on form SAR-SF); i) Assist Trust the Fund’s personnel in responding to Section 314(a) information requests; and

AML Compliance. As part of the AML program, the AMLO shall, among other things: a) Assist the Trust each Company in identifying its AML vulnerabilities and identify the risk factors relating to the AML requirements; b) Review the adequacy of the Trusteach Company’s AML program and the effectiveness of its implementation and, as necessary, make recommendations regarding updating the Trusteach Company’s AML program to accommodate changes in regulatory requirements and the Trusteach Company’s business; c) Provide ongoing AML training for appropriate persons; d) Perform testing of certain control procedures, including collecting and organizing relevant data and reviewing reports, investigating exceptions, and making inquiries of Trust each Company’s personnel and relevant Service Providers; e) Arrange for independent testing of the Funds’ AML programs; f) Monitor and review AML responsibilities that have been delegated to Service Providers; g) Conduct on-site visits of appropriate Service Providers as necessary; h) Oversee (to the extent not delegated to Service Providers) suspicious activity reporting (on form SAR-SF); i) Assist Trust each Company’s personnel in responding to Section 314(a) information requests; and

AML Compliance. As part of the AML program, the AMLO shall, among other things: a) Assist the Trust Fund in identifying its AML vulnerabilities and identify the risk factors relating to the AML requirements; b) Review the adequacy of the TrustFund’s AML program and the effectiveness of its implementation and, as necessary, make recommendations regarding updating the TrustFund’s AML program to accommodate changes in regulatory requirements and the TrustFund’s business; c) Provide ongoing AML training for appropriate persons; d) Perform testing of certain control procedures, including collecting and organizing relevant data and reviewing reports, investigating exceptions, and making inquiries of Trust the Fund personnel and relevant Service Providers; e) Arrange for independent testing of the Funds’ Fund’s AML programs; f) Monitor and review AML responsibilities that have been delegated to Service Providers; g) Conduct on-site visits of appropriate Service Providers as necessary; h) Oversee (to the extent not delegated to Service Providers) suspicious activity reporting (on form SAR-SF); i) Assist Trust the Fund’s personnel in responding to Section 314(a) information requests; and