Anti-Money Laundering and Client Screening. With respect to a Fund’s offering and sale of Shares at any time, and for all subsequent transfers of such Shares, the Funds or its delegate shall, directly or indirectly and to the extent required by law: (i) conduct know your customer/client identity due diligence with respect to potential investors and transferees in the Shares and shall obtain and retain due diligence records for each investor and transferee; (ii) use its best efforts to ensure that each investor’s and any transferee’s funds used to purchase Shares shall not be derived from, nor the product of, any criminal activity; (iii) if requested, provide periodic written verifications that such investors/transferees have been checked against the United States Department of the Treasury Office of Foreign Assets Control database for any non-compliance or exceptions; and (iv) perform its obligations under this Section in accordance with all applicable anti-money laundering laws and regulations. The Funds have engaged State Street to provide the anti-money laundering and client screening services described herein. In the event that the Transfer Agent has received advice from counsel that access to underlying due diligence records pertaining to the investors/transferees is necessary to ensure compliance by the Transfer Agent with relevant anti-money laundering (or other applicable) laws or regulations, the Funds shall, upon receipt of written request from the Transfer Agent, provide the Transfer Agent copies of such due diligence records. The parties acknowledge that, pursuant to a Supplement to this Agreement, the Transfer Agent will assist a Fund with certain aspects of its AML and Sanctions Program (as defined in the Supplement), as further detailed in the Supplement.
Appears in 2 contracts
Sources: Transfer Agency and Service Agreement (Adams Street Venture & Growth Fund), Transfer Agency and Service Agreement (Adams Street Private Equity Navigator Fund LLC)