Additional Delegated Duties Clause Samples
Additional Delegated Duties. (1) Consistent with the services provided by Transfer Agent and with respect to the ownership of shares in a Fund for which Transfer Agent maintains the applicable shareholder information, Transfer Agent shall, on behalf of each Fund and LMIS:
(i) Compare Transfer Agent’s database of Fund investor names and personal information against the OFAC SDN list and the Sanctions Programs and consult with the Fund regarding appropriate action with respect to any possible or verified matches; new accounts and account changes shall be screened daily against such lists by a Transfer Agent compliance specialist and the entire database shall be screened each time the OFAC list is updated or when the Fund submits a FinCEN Section 314(a) Information Request to the Transfer Agent;
(ii) Compare alternate payee standing instructions against the OFAC SDN list and the Sanctions Programs and consult with the Fund and LMIS regarding appropriate action with respect to any possible or verified matches;
(iii) Review redemption transactions that occur within thirty (30) days of account establishment or maintenance;
(iv) Review wires sent pursuant to banking instructions other than those on file with Transfer Agent against the OFAC SDN list and the Sanctions Programs;
(v) Review accounts with small balances followed by large purchases;
(vi) Review accounts with frequent activity within a specified date range followed by a large redemption;
(vii) On a daily basis, review purchase and redemption activity per tax identification number (“TIN”) within the Funds to determine if activity for that TIN exceeded the $100,000 threshold on any given day;
(viii) Monitor and track each incoming or outgoing payment or transfer of more than $10,000 in currency (as defined by the applicable regulations) by, through, or to the Fund or LMIS and monitor payments or transfers in currency under $10,000 for a rolling twelve-month period to determine whether an aggregate amount received in two or more related transactions has exceeded $10,000; file a Currency Transaction Report through FinCEN’s BSA E-Filing System in accordance with the applicable regulations.
(ix) Determine, in coordination with the Fund’s Chief AML Compliance Officer or his or her delegate (“AML Officer”) and, where appropriate, LMIS’ chief AML compliance officer, whether a SAR should be filed pursuant to regulations applicable to mutual funds; prepare and file a joint SAR through FinCEN’s BSA E-Filing System in accordance with the applic...
