Common use of AML Procedures2 Clause in Contracts

AML Procedures2. 4.1 Consistent with the services provided by DST and with respect to the ownership of Shares in the Trust for which DST maintains the applicable Shareholder information, DST shall: (a) On a daily basis, submit all new customer account registrations and registration changes against the Office of Foreign Assets Control (“OFAC”) database, the Politically Exposed Persons (“PEP”) database, and such other lists or databases as may be required from time to time by applicable regulatory authorities; (b) Submit all account registrations through OFAC database, the PEP database, and such other lists or databases as may be required from time to time by applicable regulatory authorities; (c) On a daily basis, submit special payee information from checks, outgoing wires and systematic withdrawal files through the OFAC database; (d) Review certain types of redemption transactions that occur within thirty-four (34) days of an account establishment, registration change, or banking information change (e.g. redemption by wire within 34 days of banking information change; rapid depletion of account balance after establishment; and redemption by check within 34 days of address change); (e) Review wires sent pursuant to banking instructions other than those on file with DST; (f) Review accounts with small balances followed by large purchases; (g) Review accounts with frequent activity within a specified date range followed by a large redemption; (h) Review purchase and redemption activity by check that meets or exceeds $100,000 threshold on any given day; (i) Determine when a suspicious activity report (“SAR”) should be filed as required by regulations applicable to mutual funds; prepare and file the SAR; provide the Trust with a copy of the SAR within a reasonable time after filing; and notify the Trust if any further communication is received from the U.S. Department of the Treasury or other law enforcement agencies regarding such filing; (j) Compare account information to any FinCEN request received by the Trust and provided to DST pursuant to USA PATRIOT Act Sec. 314(a). Provide the Trust with the necessary information for it to respond to such request within required time frame; (i) Take reasonable steps to verify the identity of any person seeking to become a new customer of the Trust and notify the Trust in the event such person cannot be verified, (ii) Maintain records of the information used to verify the person’s identity, as required, and (iii) Determine whether the person appears on any lists of known or suspected terrorists or terrorist organizations provided to the Trust by any government agency; (l) Except with respect to any entities excluded under applicable regulation: (i) take reasonable steps to verify the identity of legal entities seeking to become new customers of the Trust, including verifying the identity of the natural person(s) retaining ownership or controlling interest in such legal entity (the “ Beneficial Owner(s)”), as such ownership and controlling interests are defined in 31 C.F.R. 1010.230, (ii) notify the Trust in the event that the identity of such Beneficial Owner(s) is not provided upon request to such entity or cannot be verified, (iii) maintain records of the information used to verify such Beneficial Owners, as required, and (iv) determine whether such persons appear on any lists of known or suspected terrorists or terrorist organizations provided to the Trust by any government agency; 2 The accounts, transactions, items and activity reviewed in each case are subject to certain standard exclusions as set forth in written procedures of DST, which have been made available to the Fund and which may be modified from time to time. (m) Conduct due diligence and if required, enhanced due diligence in accordance with 31 C.F.R. 103.176(b) for new and existing correspondent accounts for foreign financial institutions (as defined in 31 C.F.R. 103.175). DST will perform an assessment of the money laundering risk presented by the account based on a consideration of relevant factors in accordance with applicable law and information provided by the foreign financial institution in a financial institution questionnaire. If an account is determined to have a medium or above risk-ranking, DST will monitor the account on a monthly basis for unusual activity. In the situation where due diligence cannot be completed with respect to an account, DST will contact the Trust’s AML Officer for further instruction. (n) Upon the request by the Trust, conduct due diligence to determine if the Trust is involved with any foreign jurisdiction, institution, class of transactions and a type of account designated, from time to time, by the U.S. Department of Justice in order to identify and take certain “special measures” against such entities as required under Section 311 of the USA PATRIOT Act (31 C.F.R. 103.193). (o) Create and retain records required under 31 CFR 103.33 in connection with the transmittals of funds in amounts equal to or in excess of $3,000, and transmit such information on the transactions to the receiving financial institutions. 4.2 In the event that DST detects activity as a result of the foregoing procedures, which necessitates the filing by DST of a SAR or other similar report or notice to OFAC, then DST shall also immediately notify the Trust, unless prohibited by applicable law. This Exhibit is made subject to the terms of the Agreement, and to the extent the terms hereunder conflict with the terms of the Agreement, the terms of this Exhibit shall prevail. The requirements of this Exhibit are applicable if and to the extent that DST creates, has access to, or receives from or on behalf of Trust any Trust Confidential Information (as defined in the Agreement) in electronic format.

AML Procedures2. 4.1 Consistent with the services provided by DST M3Sixty and with respect to the ownership of Shares shares in the Trust for which DST M3Sixty maintains the applicable Shareholder information, DST M3Sixty shall: (a) On a daily basisDaily, submit all new customer account registrations and registration changes against the Office of Foreign Assets Control (“OFAC”) database, the Politically Exposed Persons (“PEP”) database, and such other lists or databases as may be required from time to time by applicable regulatory authorities; (b) Submit all account registrations through OFAC database, the PEP database, and such other lists or databases as may be required from time to time by applicable regulatory authorities; (c) On a daily basisDaily, submit special payee information from checks, outgoing wires and systematic withdrawal files through the OFAC database; (d) Review certain types of redemption transactions that occur within thirty-four thirty (3430) days of an account establishment, registration change, or banking information change (e.g. redemption by wire within 34 30 days of banking information change; rapid depletion of account balance after establishment; and redemption by check within 34 30 days of address change); (e) Review wires sent pursuant to banking instructions other than those on file with DSTM3Sixty; (f) Review accounts with small balances followed by large purchases; (g) Review accounts with frequent activity within a specified date range followed by a large redemption; (h) Review purchase and redemption activity by check that meets or exceeds $100,000 threshold on any given day; (i) Determine when a suspicious activity report (“SAR”) should be filed as required by regulations applicable to mutual funds; prepare and file the SAR; provide the Trust with a copy of the SAR within a reasonable time after filing; and notify the Trust if any further communication is received from the U.S. Department of the Treasury or other law enforcement agencies regarding such filing;; 2 The accounts, transactions, items and activity reviewed in each case are subject to certain standard exclusions as set forth in written procedures of the Transfer Agent, which have been made available to the Fund and which may be modified from time to time. (j) Compare account information to any FinCEN request received by the Trust and provided to DST M3Sixty pursuant to USA PATRIOT Act Sec. 314(a). Provide the Trust with the necessary information for it to respond to such request within required time frame; (i) Take reasonable steps to verify the identity of any person seeking to become a new customer of the Trust and notify the Trust in the event such person cannot be verified, (ii) Maintain records of the information used to verify the person’s identity, as required, and (iii) Determine whether the person appears on any lists of known or suspected terrorists or terrorist organizations provided to the Trust by any government agency; (l) Except with respect to any entities excluded under applicable regulation: (i) take reasonable steps to verify the identity of legal entities seeking to become new customers of the Trust, including verifying the identity of the natural person(s) retaining ownership or controlling interest in such legal entity (the “ Beneficial Owner(s)”), as such ownership and controlling interests are defined in 31 C.F.R. 1010.230, (ii) notify the Trust in the event that the identity of such Beneficial Owner(s) is not provided upon request to such entity or cannot be verified, (iii) maintain records of the information used to verify such Beneficial Owners, as required, and (iv) determine whether such persons appear on any lists of known or suspected terrorists or terrorist organizations provided to the Trust by any government agency; 2 The accounts, transactions, items and activity reviewed in each case are subject to certain standard exclusions as set forth in written procedures of DST, which have been made available to the Fund and which may be modified from time to time. (m) Conduct due diligence and if required, enhanced due diligence in accordance with 31 C.F.R. 103.176(b) applicable regulations for new and existing correspondent accounts for foreign financial institutions (as defined in 31 C.F.R. 103.175the applicable regulations). DST M3Sixty will perform an assessment of the money laundering risk presented by the account based on a consideration of relevant factors in accordance with applicable law and information provided by the foreign financial institution in a financial institution questionnaire. If an account is determined to have a medium or above risk-ranking, DST M3Sixty will monitor the account on a monthly basis for unusual activity. In the situation where due diligence cannot be completed with respect to an account, DST M3Sixty will contact the Trust’s AML Officer for further instruction. (nm) Upon the request by the Trust, conduct due diligence to determine if the Trust is involved with any foreign jurisdiction, institution, class of transactions and a type of account designated, from time to time, by the U.S. Department of Justice in order to identify and take certain “special measures” against such entities as required under Section 311 of the USA PATRIOT Act (31 C.F.R. 103.193)Act. (on) Create and retain records required under 31 CFR 103.33 the “Travel Rule” in connection with the transmittals of funds in amounts equal to or in excess of $3,000, and transmit such information on the transactions to the receiving financial institutions. 4.2 In the event that DST M3Sixty detects activity as a result of the foregoing procedures, which necessitates the filing by DST M3Sixty of a SAR or other similar report or notice to OFAC, then DST M3Sixty shall also immediately notify the Trust, unless prohibited by applicable law. This Exhibit is made subject to the terms of the Agreement, and to the extent the terms hereunder conflict with the terms of the Agreement, the terms of this Exhibit shall prevail. The requirements of this Exhibit are applicable if and to the extent that DST creates, has access to, or receives from or on behalf of Trust any Trust Confidential Information (as defined in the Agreement) in electronic format.

AML Procedures2. 4.1 Consistent with the services provided by SS&C DST and with respect to the ownership of Shares units in the Trust Fund for which SS&C DST maintains the applicable Shareholder member information, SS&C DST shall: (a) On a daily basis, submit all new customer account registrations and registration changes against the Office of Foreign Assets Control (“OFAC”) database, the Politically Exposed Persons (“PEP”) database, and such other lists or databases as may be required from time to time by applicable regulatory authorities;; 2 The accounts, transactions, items and activity reviewed in each case are subject to certain standard exclusions as set forth in written procedures of SS&C DST, which have been made available to the Fund and which may be modified from time to time. (b) Submit all account registrations through OFAC database, the PEP database, and such other lists or databases as may be required from time to time by applicable regulatory authorities; (c) On a daily basis, submit special payee information from checks, outgoing wires and systematic withdrawal files through the OFAC database; (d) Review certain types of redemption transactions that occur within thirty-four (34) days of an account establishment, registration change, or banking information change (e.g. redemption by wire within 34 days of banking information change; rapid depletion of account balance after establishment; and redemption by check within 34 days of address change); (e) Review wires sent pursuant to banking instructions other than those on file with SS&C DST; (f) Review accounts with small balances followed by large purchases; (g) Review accounts with frequent activity within a specified date range followed by a large redemption; (h) Review purchase and redemption activity by check that meets or exceeds $100,000 threshold on any given day; (i) Determine when a suspicious activity report (“SAR”) should be filed as required by regulations applicable to mutual funds; prepare and file the SAR; provide the Trust Fund with a copy of the SAR within a reasonable time after filing; and notify the Trust Fund if any further communication is received from the U.S. Department of the Treasury or other law enforcement agencies regarding such filing; (j) Compare account information to any FinCEN request received by the Trust Fund and provided to SS&C DST pursuant to USA PATRIOT Act Sec. 314(a). Provide the Trust Fund with the necessary information for it to respond to such request within required time frame; (i) Take reasonable steps to verify the identity of any person seeking to become a new customer of the Trust Fund and notify the Trust Fund in the event such person cannot be verified, (ii) Maintain records of the information used to verify the person’s identity, as required, and (iii) Determine whether the person appears on any lists of known or suspected terrorists or terrorist organizations provided to the Trust Fund by any government agency; (l) Except with respect to any entities excluded under applicable regulation: (i) take reasonable steps to verify the identity of legal entities seeking to become new customers of the TrustFund, including verifying the identity of the natural person(s) retaining ownership or controlling interest in such legal entity (the “ Beneficial Owner(s)”), as such ownership and controlling interests are defined in 31 C.F.R. 1010.230, (ii) notify the Trust Fund in the event that the identity of such Beneficial Owner(s) is not provided upon request to such entity or cannot be verified, (iii) maintain records of the information used to verify such Beneficial Owners, as required, and (iv) determine whether such persons appear on any lists of known or suspected terrorists or terrorist organizations provided to the Trust Fund by any government agency; 2 The accounts, transactions, items and activity reviewed in each case are subject to certain standard exclusions as set forth in written procedures of DST, which have been made available to the Fund and which may be modified from time to time.; (m) Conduct due diligence and if required, enhanced due diligence in accordance with 31 C.F.R. 103.176(b) for new and existing correspondent accounts for foreign financial institutions (as defined in 31 C.F.R. 103.175). SS&C DST will perform an assessment of the money laundering risk presented by the account based on a consideration of relevant factors in accordance with applicable law and information provided by the foreign financial institution in a financial institution questionnaire. If an account is determined to have a medium or above risk-ranking, SS&C DST will monitor the account on a monthly basis for unusual activity. In the situation where due diligence cannot be completed with respect to an account, SS&C DST will contact the TrustFund’s AML Officer for further instruction. (n) Upon the request by the TrustFund, conduct due diligence to determine if the Trust Fund is involved with any foreign jurisdiction, institution, class of transactions and a type of account designated, from time to time, by the U.S. Department of Justice in order to identify and take certain “special measures” against such entities as required under Section 311 of the USA PATRIOT Act (31 C.F.R. 103.193). (o) Create and retain records required under 31 CFR 103.33 in connection with the transmittals of funds in amounts equal to or in excess of $3,000, and transmit such information on the transactions to the receiving financial institutions. 4.2 4.1 In the event that SS&C DST detects activity as a result of the foregoing procedures, which necessitates the filing by SS&C DST of a SAR or other similar report or notice to OFAC, then SS&C DST shall also immediately notify the TrustFund, unless prohibited by applicable law. This Exhibit is made subject to the terms of the Agreement, and to the extent the terms hereunder conflict with the terms of the Agreement, the terms of this Exhibit shall prevail. The requirements of this Exhibit are applicable if and to the extent that DST creates, has access to, or receives from or on behalf of Trust any Trust Confidential Information (as defined in the Agreement) in electronic format.