Common use of AML Services Clause in Contracts

AML Services. The Trust delegates to Atlantic the performance of the anti-money laundering services set forth below (the “AML Services”) with respect to shareholder accounts maintained by Atlantic pursuant to the Agreement; and subject to the terms and conditions of the Agreement, Atlantic accepts this delegation and agrees to perform the AML Services in accordance with the Trust’s and Atlantic’s AML program and reasonably to cooperate with the Trust’s AML compliance officer (the “AML Compliance Officer”) in the performance of that person’s responsibilities. 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 applicable AML laws. (a) Verify shareholder identity upon opening new customer 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 Trust and Atlantic; (c) Review all new accounts and registration maintenance transactions against the Office of Foreign Asset Control (“OFAC”) database and other 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 the Trust’s policies with respect to the acceptance of cash equivalents and third party checks; provided, however, that unless the parties agree otherwise under no circumstance will Atlantic accept a corporate third party check; (e) Place holds on transactions in shareholder accounts or freeze shareholder accounts, as provided in the AML programs of the Trust and Atlantic and in accordance with the Patriot Act and OFAC; (f) (i) Atlantic will 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 Trust's AML program as in effect from time-to-time, (ii) conduct (or have a third party conduct) an independent review of its AML Program at least annually and provide the report of such independent review to the Trust and the Trust’s AML Compliance Officer; and (iii) maintain a reasonable, ongoing training program with respect to its own personnel relating to AML matters.

AML Services. The Trust delegates to Atlantic Citibank the performance of the anti-money laundering services set forth below (the “"AML Services”") with respect to shareholder accounts maintained by Atlantic Citibank pursuant to the Agreement; and subject to the terms and conditions of the Agreement, Atlantic Citibank accepts this delegation and agrees to perform the AML Services in accordance with the Trust’s 's and Atlantic’s Citibank's AML program and reasonably to cooperate with the Trust’s 's AML compliance officer (the “"AML Compliance Officer”") in the performance of that person’s 's responsibilities. Notwithstanding this delegation, the Trust shall maintain full responsibility for ensuring that its APPENDIX E - TRANSFER AGENCY SERVICES AML program is and continues to be reasonably designed to ensure compliance with the applicable AML laws. (a) 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 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 Trust and AtlanticCitibank; (c) Review all new accounts and registration maintenance transactions against the Office of Foreign Asset Control (“"OFAC”") database and other 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 the Trust’s 's policies with respect to the acceptance of cash equivalents and third party checks; provided, however, that unless the parties agree otherwise under no circumstance will Atlantic Citibank accept a corporate third party check; (e) Place holds on transactions in shareholder accounts or freeze shareholder accounts, as provided in the AML programs of the Trust and Atlantic Citibank and in accordance with the Patriot Act and OFAC; (f) (i) Atlantic will 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 Trust's AML program as in effect from time-to-time, (ii) conduct (or have a third party conduct) an independent review of its AML Program at least annually and provide the report of such independent review to the Trust and the Trust’s AML Compliance Officer; and (iii) maintain a reasonable, ongoing training program with respect to its own personnel relating to AML matters.

AML Services. The Trust delegates to Atlantic the performance of the anti-money laundering services set forth below (the “AML Services”) with respect to shareholder accounts maintained by Atlantic pursuant to the Agreement; and subject to the terms and conditions of the Agreement, Atlantic accepts this delegation and agrees to perform the AML Services in accordance with the Trust’s and Atlantic’s AML program and reasonably to cooperate with the Trust’s AML compliance officer (the “AML Compliance Officer”) in the performance of that person’s responsibilities. 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 applicable AML laws. (a) Verify shareholder identity upon opening new customer 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 Trust and Atlantic; (c) Review all new accounts and registration maintenance transactions against the Office of Foreign Asset Control (“OFAC”) database and other 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 the Trust’s policies with respect to the acceptance of cash equivalents and third party checks; provided, however, that unless the parties agree otherwise under no circumstance will Atlantic accept a corporate third party check; (e) Place holds on transactions in shareholder accounts or freeze shareholder accounts, as provided in the AML programs program of the Trust and Atlantic AML Policies and Procedures and in accordance with the Patriot Act and OFAC; (f) (i) Atlantic will 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 Trust's ’s AML program as in effect from time-to-time, (ii) conduct (or have a third party conduct) an independent review of its AML Program at least annually and provide the report of such independent review to the Trust and the Trust’s AML Compliance Officer; and (iii) maintain a reasonable, ongoing training program with respect to its own personnel relating to AML matters.

AML Services. The Trust delegates to Atlantic the performance of the anti-money laundering services set forth below below, including the related recordkeeping required by the Trust's AML Program, (the “"AML Services”") with respect to shareholder accounts maintained by Atlantic pursuant to the Agreement; and subject to the terms and conditions of the Agreement, Atlantic accepts this delegation and agrees to perform the AML Services in accordance with the Trust’s 's and Atlantic’s 's AML program and reasonably to cooperate with the Trust’s 's AML compliance officer (the “"AML Compliance Officer”") in the performance of that person’s 's responsibilities. 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 applicable AML laws.: (a) Verify shareholder identity upon opening new customer accounts in accordance with Section Sections 312 and 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 Trust and Atlantic; (c) Review all new accounts and registration maintenance transactions against the Office of Foreign Asset Control (“"OFAC”") database and other 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 the Trust’s 's policies with respect to the acceptance of cash equivalents and third party checks; provided, however, that unless the parties agree otherwise under no circumstance will Atlantic accept a corporate third party check; (e) Place holds on transactions in shareholder accounts or freeze shareholder accounts, as provided in the AML programs of the Trust and Atlantic and in accordance with the Patriot Act and OFAC; (f) (i) Atlantic will reasonably cooperate with subject to the Trust to accommodate non-material changes and adjustments to agreed upon servicesChange Control Process, maintaining maintain reasonably adequate policies, procedures and internal controls that are consistent with the Trust's AML program as in effect from time-to-time, (ii) conduct (or have a third party conduct) an independent review of its AML Program at least annually and provide the report of such independent review to the Trust and the Trust’s 's AML Compliance Officer; and (iii) maintain a reasonable, ongoing training program with respect to its own personnel relating to AML matters; and (g) Review all new and existing accounts against lists provided by FinCEN as set out in Section 314 of the Patriot Act and any regulations thereunder, and pursuant to Section 314, i) report identified accounts to FinCEN, and ii) maintain the security of information requests; Notwithstanding the foregoing 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 applicable AML laws.

AML Services. The Trust delegates to Atlantic the performance of the anti-money laundering services set forth below (the “"AML Services”") with respect to shareholder accounts maintained by Atlantic pursuant to the this Agreement; and subject to the terms and conditions of the this Agreement, Atlantic accepts this delegation and agrees to perform the AML Services in accordance with the Trust’s and Atlantic’s 's AML program and reasonably to cooperate with the Trust’s 's AML compliance officer (the “"AML Compliance Officer”") in the performance of that person’s 's responsibilities. 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 applicable AML laws. (a) Verify shareholder identity upon opening new customer 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 Trust and Atlantic; (c) Review all new accounts and registration maintenance transactions against the Office of Foreign Asset Control (“"OFAC”") database and other 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 the Trust’s 's policies with respect to the acceptance of cash equivalents and third party checks; provided, however, that unless the parties agree otherwise under no circumstance will Atlantic accept a corporate third party check; (e) Place holds on transactions in shareholder accounts or freeze shareholder accounts, as provided in the AML programs of the Trust and the AML policies and procedures of Atlantic and in accordance with the Patriot Act and OFAC; (f) (i) Atlantic will 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 Trust's AML program as in effect from time-to-time, (ii) conduct (or have a third party conduct) an independent review of its AML Program Policies and Procedures at least annually and provide the report of such independent review to the Trust and the Trust’s 's AML Compliance Officer; and (iii) maintain a reasonable, ongoing training program with respect to its own personnel relating to AML matters.

AML Services. The Trust delegates to Atlantic the performance of the anti-money laundering services set forth below (the “"AML Services”") with respect to shareholder accounts maintained by Atlantic pursuant to the Agreement; and subject to the terms and conditions of the Agreement, Atlantic accepts this delegation and agrees to perform the AML Services in accordance with the Trust’s 's and Atlantic’s 's AML program and reasonably to cooperate with the Trust’s 's AML compliance officer (the “"AML Compliance Officer”") in the performance of that person’s 's responsibilities. 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 applicable AML laws. (a) Verify shareholder identity upon opening new customer 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 Trust and Atlantic; (c) Review all new accounts and registration maintenance transactions against the Office of Foreign Asset Control (“"OFAC”") database and other 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 the Trust’s 's policies with respect to the acceptance of cash equivalents and third party checks; provided, however, that unless the parties agree otherwise under no circumstance will Atlantic accept a corporate third party check; (e) Place holds on transactions in shareholder accounts or freeze shareholder accounts, as provided in the AML programs of the Trust and Atlantic and in accordance with the Patriot Act and OFAC; (f) (i) Atlantic will 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 Trust's AML program as in effect from time-to-time, (ii) conduct (or have a third party conduct) an independent review of its AML Program at least annually and provide the report of such independent review to the Trust and the Trust’s 's AML Compliance Officer; and (iii) maintain a reasonable, ongoing training program with respect to its own personnel relating to AML matters.

AML Services. The Trust delegates to Atlantic the performance of the anti-money laundering services set forth below (the “AML Services”) with respect to shareholder accounts maintained by Atlantic pursuant to the Agreement; and subject to the terms and conditions of the Agreement, Atlantic accepts this delegation and agrees to perform the AML Services in accordance with the Trust’s and Atlantic’s AML program and reasonably to cooperate with the Trust’s AML compliance officer (the “AML Compliance Officer”) in the performance of that person’s responsibilities. 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 applicable AML laws. (a) Verify shareholder identity upon opening new customer 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 Trust and Atlantic; (c) Review all new accounts and registration maintenance transactions against the Office of Foreign Asset Control (“OFAC”) database and other 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 the Trust’s policies with respect to the acceptance of cash equivalents and third third-party checks; provided, however, that unless the parties agree otherwise under no circumstance will Atlantic accept a corporate third third-party check; (e) Place holds on transactions in shareholder accounts or freeze shareholder accounts, as provided in the AML programs of the Trust and the AML policies and procedures of Atlantic and in accordance with the Patriot Act and OFAC; (f) (i) Atlantic will 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 Trust's AML program as in effect from time-to-time, (ii) conduct (or have a third party conduct) an independent review of its AML Program Policies and Procedures at least annually and provide the report of such independent review to the Trust and the Trust’s AML Compliance Officer; and (iii) maintain a reasonable, ongoing training program with respect to its own personnel relating to AML matters.

AML Services. The Trust delegates to Atlantic the performance of the anti-money laundering services set forth below (the “"AML Services”") with respect to shareholder accounts maintained by Atlantic pursuant to the Agreement; and subject to the terms and conditions of the Agreement, Atlantic accepts this delegation and agrees to perform the AML Services in accordance with the Trust’s 's and Atlantic’s 's AML program and reasonably to cooperate with the Trust’s 's AML compliance officer (the “"AML Compliance Officer”") in the performance of that person’s 's responsibilities. 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 applicable AML laws. (a) Verify shareholder identity upon opening new customer accounts in accordance with Section 326 of the USA PATRIOT Act (the “"Patriot Act”") and any regulations thereunder, as required under Applicable Law; (b) Identify and verify beneficial owner of legal entitied in accordance with the rules adopted by The Financial Crimes Enforcement Network (FinCEN); (c) 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 Trust and Atlantic; (cd) Review all new accounts and registration maintenance transactions against the Office of Foreign Asset Control (“"OFAC”") database and other 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; (de) Follow the Trust’s 's policies with respect to the acceptance of cash equivalents and third party checks; provided, however, that unless the parties agree otherwise under no circumstance will Atlantic accept a corporate third party check; (ef) Place holds on transactions in shareholder accounts or freeze shareholder accounts, as provided in the AML programs of the Trust and Atlantic and in accordance with the Patriot Act and OFAC; (f) (i) Atlantic will 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 Trust's AML program as in effect from time-to-time, (ii) conduct (or have a third party conduct) an independent review of its AML Program at least annually and provide the report of such independent review to the Trust and the Trust’s 's AML Compliance Officer; and (iii) maintain a reasonable, ongoing training program with respect to its own personnel relating to AML matters.

AML Services. The Trust delegates to Atlantic the performance of the anti-money laundering services set forth below (the “AML Services”) with respect to shareholder accounts maintained by Atlantic pursuant to the this Agreement; and subject to the terms and conditions of the this Agreement, Atlantic accepts this delegation and agrees to perform the AML Services in accordance with the Trust’s and Atlantic’s AML program and reasonably to cooperate with the Trust’s AML compliance officer (the “AML Compliance Officer”) in the performance of that person’s responsibilities. 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 applicable AML laws. (a) Verify shareholder identity upon opening new customer 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 Trust and Atlantic; (c) Review all new accounts and registration maintenance transactions against the Office of Foreign Asset Control (“OFAC”) database and other 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 the Trust’s policies with respect to the acceptance of cash equivalents and third party checks; provided, however, that unless the parties agree otherwise under no circumstance will Atlantic accept a corporate third party check; (e) Place holds on transactions in shareholder accounts or freeze shareholder accounts, as provided in the AML programs of the Trust and the AML policies and procedures of Atlantic and in accordance with the Patriot Act and OFAC; (f) (i) Atlantic will 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 Trust's ’s AML program as in effect from time-to-time, (ii) conduct (or have a third party conduct) an independent review of its AML Program Policies and Procedures at least annually and provide the report of such independent review to the Trust and the Trust’s AML Compliance Officer; and arid (iii) maintain a reasonable, ongoing training program with respect to its own personnel relating to AML matters.

AML Services. The Trust delegates to Atlantic the performance of the anti-money laundering services set forth below below, including the related recordkeeping required by the Trust's AML Program, (the “"AML Services”") with respect to shareholder accounts maintained by Atlantic pursuant to the Agreement; and subject to the terms and conditions of the Agreement, Atlantic accepts this delegation and agrees to perform the AML Services in accordance with the Trust’s 's and Atlantic’s 's AML program and reasonably to cooperate with the Trust’s 's AML compliance officer (the “"AML Compliance Officer”") in the performance of that person’s 's responsibilities. 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 applicable AML laws.: (a) Verify shareholder identity upon opening new customer accounts in accordance with Section Sections 312 and 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 Trust and Atlantic; (c) Review all new accounts and registration maintenance transactions against the Office of Foreign Asset Control (“"OFAC”") database and other 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 the Trust’s 's policies with respect to the acceptance of cash equivalents and third party checks; provided, however, that unless the parties agree otherwise under no circumstance will Atlantic accept a corporate third party check; (e) Place holds on transactions in shareholder accounts or freeze shareholder accounts, as provided in the AML programs of the Trust and Atlantic and in accordance with the Patriot Act and OFAC; (f) (i) Atlantic will reasonably cooperate with subject to the Trust to accommodate non-material changes and adjustments to agreed upon servicesChange Control Process, maintaining maintain reasonably adequate policies, procedures and internal controls that are consistent with the Trust's AML program as in effect from time-to-time, (ii) conduct (or have a third party conduct) an independent review of its AML Program at least annually and provide the report of such independent review to the Trust and the Trust’s 's AML Compliance Officer; and (iii) maintain a reasonable, ongoing training program with respect to its own personnel relating to AML matters; and (g) Review all new and existing accounts against lists provided by XxxXXX as set out in Section 314 of the Patriot Act and any regulations thereunder, and pursuant to Section 314, i) report identified accounts to FinCEN, and ii) maintain the security of information requests; Notwithstanding the foregoing 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 applicable AML laws.

AML Services. (a) The Trust hereby delegates to Atlantic Ultimus the performance performance, on behalf of the Trust, of the anti-money laundering services (the "AML Services") set forth below (in Schedule C to this Agreement as concerns the “AML Services”) with respect to shareholder accounts maintained by Atlantic Ultimus pursuant to the AgreementAgreement (including direct accounts; accounts maintained through FUND/SERV and Networking; and subject omnibus accounts). Ultimus agrees to the terms and conditions of the Agreement, Atlantic accepts this foregoing delegation and agrees to perform the AML Services delegated services in accordance with the Trust’s and Atlantic’s AML anti-money laundering program and reasonably to cooperate with that has been adopted by the Trust’s AML compliance officer Trust (the “"AML Compliance Officer”) in the performance of that person’s responsibilitiesProgram). Notwithstanding this delegationIn connection therewith, the Trust shall Ultimus agrees to maintain full responsibility for ensuring that its AML program is policies and continues to be reasonably designed to ensure compliance with the applicable AML laws. (a) Verify shareholder identity upon opening new customer accounts in accordance with Section 326 of the USA PATRIOT Act (the “Patriot Act”) procedures, and any regulations thereunderrelated internal controls, 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 Trust and Atlantic; (c) Review all new accounts and registration maintenance transactions against the Office of Foreign Asset Control (“OFAC”) database and other 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 the Trust’s policies with respect to the acceptance of cash equivalents and third party checks; provided, however, that unless the parties agree otherwise under no circumstance will Atlantic accept a corporate third party check; (e) Place holds on transactions in shareholder accounts or freeze shareholder accounts, as provided in the AML programs of the Trust and Atlantic and in accordance with the Patriot Act and OFAC; (f) (i) Atlantic will 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 Trust's AML program as Program and the requirement that the Trust employ procedures reasonably designed to achieve compliance with the applicable anti-money laundering laws (the "Applicable AML Laws"), including the requirement to have policies and procedures that can be reasonably expected to detect and cause the reporting of transactions under Section 5318 of the Bank Secrecy Act. (b) The Trust agrees and acknowledges that, notwithstanding the delegation provided for in effect from time-to-timethe foregoing paragraph, (ii) conduct (or have a third party conduct) an independent review of the Trust maintains full responsibility for ensuring that its AML Program at least annually is, and provide shall continue to be, reasonably designed to ensure compliance with the report Applicable AML Laws, in light of the particular business of the Trust, taking into account factors such independent review as its size, location, activities and risks or vulnerabilities to money laundering. (c) In connection with the foregoing delegation, the Trust also acknowledges that the performance of the AML Services enumerated in Schedule C involves the exercise of discretion, which in certain circumstances may result in consequences to the Trust and its shareholders (such as in the Trust’s case of the reporting of suspicious activities and the freezing of shareholder accounts). In this regard, (i) under the circumstances in which the AML Compliance Officer; Program authorizes the taking of certain actions, Ultimus is granted the discretion to take any such action as may be authorized, and consultation with the Trust shall not be required in connection therewith unless expressly required by the AML Program, and (iiiii) maintain the Trust instructs Ultimus that it may avail the Trust of any safe harbor from civil liability that may be available under Applicable AML Laws for making a reasonabledisclosure or filing a report thereunder. (d) At least quarterly, ongoing training program with respect Ultimus shall provide a report to its own personnel relating to AML mattersthe Trust containing the information listed on Schedule D hereto.

AML Services. The Trust delegates to Atlantic the performance of the anti-money laundering services set forth below (the “"AML Services”") with respect to shareholder accounts maintained by Atlantic pursuant to the this Agreement; and subject to the terms and conditions of the this Agreement, Atlantic accepts this delegation and agrees to perform the AML Services in accordance with the Trust’s 's and Atlantic’s 's AML program and reasonably to cooperate with the Trust’s 's AML compliance officer (the “"AML Compliance Officer”") in the performance of that person’s 's responsibilities. 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 applicable AML laws. (a) Verify shareholder identity upon opening new customer 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 Trust and Atlantic; (c) Review all new accounts and registration maintenance transactions against the Office of Foreign Asset Control (“"OFAC”") database and other 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 the Trust’s 's policies with respect to the acceptance of cash equivalents and third party checks; provided, however, that unless the parties agree otherwise under no circumstance will Atlantic accept a corporate third party check; (e) Place holds on transactions in shareholder accounts or freeze shareholder accounts, as provided in the AML programs of the Trust and Atlantic and in accordance with the Patriot Act and OFAC; (f) (i) Atlantic will 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 Trust's AML program as in effect from time-to-time, (ii) conduct (or have a third party conduct) an independent review of its AML Program at least annually and provide the report of such independent review to the Trust and the Trust’s 's AML Compliance Officer; and (iii) maintain a reasonable, ongoing training program with respect to its own personnel relating to AML matters.