Anti-Money Laundering Services. In each case consistent with and as required or permitted by the written anti-money laundering program of the Client (“AML Program”):
Anti-Money Laundering Services. (a) Verify shareholder identity upon opening new accounts.
Anti-Money Laundering Services. (a) Where appropriate and information is available, verify shareholder identity upon opening new accounts.
Anti-Money Laundering Services. BNYM shall perform the AML Services (as defined in Appendix C) in accordance with the terms of Appendix C.
Anti-Money Laundering Services. Administrator shall: (a) establish and implement written internal policies, procedures and controls reasonably designed to assist the Fund with any obligations it may have under the USA PATRIOT Act, the Bank Secrecy Act of 1970, the customer identification rules jointly adopted by the Commission and the U.S. Treasury Department and other applicable regulations adopted thereunder (the "AML Laws"; (b) provide for independent testing, by an employee who is not responsible for the operation of Administrator's anti-money laundering ("AML") program or by an outside party, for compliance with Administrator's written AML policies and procedures; (c) designate a person or persons responsible for implementing and monitoring the operation and internal controls of Administrator's AML program; and (d) provide ongoing training of Administrator personnel relating to the prevention of money-laundering activities. Upon the reasonable request of the Fund, Administrator shall provide to the Fund: (x) a copy of Administrator's written AML policies and procedures; (y) a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; and (z) a summary of the AML training provided for appropriate Administrator personnel.
Anti-Money Laundering Services. The Trust hereby delegates to you, and you agree to accept the delegation of, the performance, on behalf of the Trust, of those anti-money laundering services (the "AML Services") set forth in Exhibit B concerning those retailing broker-dealers that open accounts with the Trust in order to purchase creation units of the Trust's Funds into inventory and then sell them to the public. You agree to the foregoing delegation and agree that you will perform the delegated AML Services in accordance with the Trust's AML Program. In connection therewith, you agree to maintain policies and procedures, and related internal controls, that are consistent with the Trust's AML Program and the requirement that the Trust employ procedures reasonably designed to achieve compliance with applicable anti-money laundering laws, regulations and rules, including the requirement to have policies and procedures that can be reasonably expected to detect and cause the reporting of transactions under the Bank Secrecy Act, as amended by the USA PATRIOT Act of 2001. You also agree to keep and maintain on behalf of the Trust all books and records which the Trust and you are, or may be, required to keep and maintain pursuant to any applicable laws, regulations, and rules, including without limitation Rules 31a-1 and 31a-2 under the 1940 Act, relating to the maintenance of books and records in connection with the AML services to be provided hereunder. You further agree that all such books and records shall be the property of the Trust and to make such books and records available for inspection by the Trust or by the Trust's regulators, including the SEC, at reasonable times and otherwise to keep confidential all books and records and other information relative to the Trust and its shareholders consistent with the requirements of Regulation S-P.
Anti-Money Laundering Services. (A) ADOPTION OF ANTI-MONEY LAUNDERING PROGRAM AND DELEGATION OF SERVICES TO THE ADMINISTRATOR. The Trust hereby delegates to the Administrator the performance, on behalf of the Trust, of the services set forth in Schedule C hereto (the "AML Services") with respect to all Shareholder accounts maintained by the Administrator pursuant to this Agreement. The Administrator accepts this delegation and agrees to perform or supervise the performance of the AML Services in accordance with the Trust's AML Program and the Administrator's anti-money laundering program and to cooperate with the Trust's AML Compliance Officer in the performance of its responsibilities hereunder. The Administrator may employ SIMC and may sub-contract with other affiliated or non-affiliated third parties to perform all or part of the services to be performed by the Administrator under this Article 4; provided, however, that the Administrator shall remain responsible to the Trust for the acts and omissions of SIMC and such sub-contracted parties. The Administrator will certify annually to the Trust that it has implemented the Trust's AML Program, and that the Administrator (or its agent) will perform the specific requirements of the Trust's AML Program delegated to the Administrator. Notwithstanding this delegation, the Trust shall maintain full responsibility for ensuring that its AML Program is and continues to be reasonably designed to ensure compliance with the USA Patriot Act and Bank Secrecy Act (collectively, the "AML Acts") and any regulation adopted under the AML Acts (the "Applicable AML Laws"). The Administrator shall maintain policies, procedures and internal controls that are consistent with the Trust's AML Program and the requirement that the Trust employ procedures reasonably designed to achieve compliance with the Applicable AML Laws and the Trust's AML Program. The Trust recognizes that the performance of the AML Services involves the exercise of discretion, which in certain circumstances may result in consequences to the Trust and its Shareholders (such as in the case of the reporting of suspicious activities and the freezing of Shareholders' accounts). The Trust authorizes the Administrator to take such actions in the performance of the AML Services as the Administrator deems appropriate and consistent with the Trust's AML Program and Applicable AML Laws.
Anti-Money Laundering Services. Verify shareholder identity upon opening new accounts where the subscription comes directly to X.X. Xxxxxx. X.X. Xxxxxx will monitor, identify and report shareholder transactions and identify and report suspicious activities that are required to be so identified and reported, and provide other required reports to the Securities and Exchange Commission, the U.S. Treasury Department, the Internal Revenue Service or each agency’s designated agent, in each case consistent with X.X Xxxxxx’x or the Funds’ AML Program, as provided to X.X. Xxxxxx and approved by X.X. Xxxxxx from time to time (“AML Program”). X.X. Xxxxxx will place holds on transactions in shareholder accounts or freeze assets in shareholder accounts, as provided in the AML Program and create documentation to provide a basis for law enforcement authorities to trace illicit funds. X.X. Xxxxxx will maintain all records or other documentation related to shareholder accounts and transactions therein that are required to be prepared and maintained pursuant to the AML Program, and make the same available for inspection by (i) the designated AML Compliance Officer, (ii) any auditor of the Funds’ AML Program or related procedures, policies or controls that have been designated by the Fund in writing, or (iii) regulatory or law enforcement authorities, and otherwise make said records or other documents available at the direction of the designated AML Compliance Officer.
Anti-Money Laundering Services. In recognition of the importance of complying with the USA Patriot Act of 2001 and the regulations promulgated thereunder (collectively, the “Patriot Act”) and the Regulations, which impose anti-money laundering requirements on financial institutions, GFS has developed and implemented a written anti-money laundering program (“Program”) designed to satisfy the requirements of the Patriot Act and the Regulations.
Anti-Money Laundering Services. PNC has in place programs to ensure compliance with Section 352 of the USA PATRIOT Act and 31 CFR § 103.130 dealing with anti-money laundering (“AML”) programs, Section 326 of the USA PATRIOT Act dealing with Customer Identification Programs (“CIP”), Office of Foreign Asset Control (“OFAC”) economic sanctions programs, 31 CFR § 103.15 dealing with the filing of Suspicious Activity Reports (“SARs”), preparation and filing of Internal Revenue Service (“IRS”)/Financial Crimes Enforcement Network (“FinCEN”) Form 8300 filings and required notices, responding to FinCEN Section 314(a) Information Requests, Section 312 of the USA PATRIOT Act requirements to establish and implement a due diligence program for “foreign financial institution” accounts, Section 311 of the USA PATRIOT Act requirements related to primary money laundering concerns (“PMLCs”), and the program of The Financial Action Task Force (“FATF”) related to non-cooperative countries or territories (“NCCT’s”). PNC has agreed to assist the Fund in meeting its compliance with Section 352 of the USA PATRIOT Act, Section 326 of the USA PATRIOT Act and 31 CFR § 103.130 dealing with AML programs, dealing with CIP, compliance with 31 CFR § 103.15 dealing with the filing of SARs, in complying with OFAC economic sanctions programs, with respect to preparing and filing IRS/FinCEN filings and notices, responding to FinCEN Section 314(a) Information Requests, compliance with Section 312 of the USA PATRIOT Act dealing with due diligence for “foreign financial institution” accounts, compliance with Section 311 of the USA PATRIOT Act dealing with PMLCs, and the FATF’s NCCT program as set forth herein.
