Processing Distributions. Prepare and, subject to receipt of good funds therefor from the custodian for the applicable Fund, transmit to Shareholders (or credit the appropriate Shareholder accounts) payments for all distributions declared by the Client with respect to Shares of a Fund. 4.1 ANTI-MONEY LAUNDERING ("AML") MATTERS ("AML SERVICES") The Client delegates to Citigroup the performance of the services set forth below (the "AML Services") with respect to shareholder accounts maintained by Citigroup pursuant to the Agreement; and subject to the terms and conditions of the Agreement, Citigroup accepts this delegation and agrees to perform the AML Services in accordance with the Client's and Citigroup's AML program. Notwithstanding this delegation, the Client shall maintain full responsibility for ensuring that its AML program is and continues to be reasonably designed to ensure compliance with the applicable AML laws. (a) Verify shareholder identity upon opening new accounts in accordance with Section 326 of the USA PATRIOT Act (the "PATRIOT ACT") and any regulations thereunder, as required under applicable law; (b) Monitor shareholder transactions and identify and report suspicious activities that are required to be so identified and reported, in each case consistent with the AML programs of the Client and Citigroup; (c) Submit all accounts through the Office of Foreign Asset Control ("OFAC") database and FinCEN's Control List; (d) Follow the Client's third party check policies; provided, however, that under no circumstance will Citigroup accept a corporate third party check; (e) Place holds on transactions in shareholder accounts or freeze assets in shareholder accounts, as provided in the AML programs of the Client and Citigroup and in accordance with the Patriot Act and OFAC; and (f) Maintain policies, procedures and internal controls that are consistent with the Client's AML program C-3 (Transfer Agency)
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Sources: Transfer Agency Services Agreement (Wintergreen Fund, Inc.)
Processing Distributions. Prepare and, subject to receipt of good funds therefor from the custodian for the applicable Fund, transmit to Shareholders (or credit the appropriate Shareholder accounts) payments for all distributions declared by the Client Trust with respect to Shares of a Fund.
4.1 ANTIAnti-MONEY LAUNDERING Money Laundering ("“AML"”) MATTERS ("AML SERVICES") The Client delegates to Citigroup the performance of the services set forth below (the "AML Services") with respect to shareholder accounts maintained by Citigroup pursuant to the Agreement; and subject to the terms and conditions of the Agreement, Citigroup accepts this delegation and agrees to perform the AML Services in accordance with the Client's and Citigroup's AML program. Notwithstanding this delegation, the Client shall maintain full responsibility for ensuring that its AML program is and continues to be reasonably designed to ensure compliance with the applicable AML laws.
(a) Verify Execute the Trust’s customer identification program and otherwise verify shareholder identity upon opening new customer accounts in accordance with Section 326 of the USA PATRIOT Act (the "PATRIOT ACT"“Patriot Act”) and any regulations thereunder, as required under applicable lawApplicable Law;
(b) Monitor shareholder transactions and identify and report suspicious activities that are required to be so identified and reported, in each case consistent with the AML programs of the Client Trust and CitigroupAtlantic TA;
(c) Submit Screen for prohibited shareholders, which may include reviewing all new accounts through and registration maintenance transactions against the Office of Foreign Asset Control ("“OFAC"”) database and FinCEN's Control Listother such lists or databases of trade restricted individuals or entities as may be required from time to time by applicable regulatory authorities, including review of such shareholder information upon changes to such databases;
(d) Follow Identify correspondent accounts and applications subject to the Client's due diligence requirements of Section 312 of the Patriot Act and prompt reporting of such identification to the appropriate AML Compliance Officer;
(e) Administer the Trust’s policies with respect to the form of payment policy, including instructions for acceptance of cash equivalents and third party check policieschecks; provided, however, that unless the parties agree otherwise under no circumstance will Citigroup Atlantic TA accept a corporate third party check;
(ef) Place holds on transactions in shareholder accounts or freeze assets in shareholder accounts, as provided in the AML programs program of the Client and Citigroup Trust and in accordance with the Patriot Act and OFAC; and;
(fg) Maintain Atlantic TA will (i) reasonably cooperate with the Trust to accommodate non-material changes and adjustments to agreed upon services, maintaining reasonably adequate policies, procedures and internal controls that are consistent with the ClientTrust's AML program C-3 as in effect from time-to-time, (Transfer Agency)ii) conduct (or have a third party conduct) an independent review of its AML Policies and Procedures at least annually and provide the report of such independent review to the Trust and the Trust’s AML Compliance Officer; (iii) perform certain record keeping duties in accordance with the Trust’s AML program; (iv) transmit certain shareholder information only as necessary to comply with the Trust’s AML program, including administration of the Travel Rule; and (v) maintain a reasonable, ongoing training program with respect to its own personnel relating to AML matters.
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