AML Services. The Trust delegates to Ultimus the performance of the anti-money laundering services set forth below (the “AML Services”) with respect to investor accounts maintained by Ultimus pursuant to the Agreement; and subject to the terms and conditions of the Agreement, Ultimus accepts this delegation and agrees to perform the AML Services in accordance with the Fund’s and Ultimus’ AML program and reasonably to cooperate with the Fund AML Officer in the performance of that person’s responsibilities. Notwithstanding this delegation, the Fund 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. (i) Verify investor 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; (ii) Monitor investor 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 Fund and Ultimus; (iii) 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 investor information upon changes to such databases; (iv) Follow the Fund’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 Ultimus accept a corporate third party check; (v) Place holds on transactions in investor accounts or freeze investor accounts, as provided in the AML programs of the Fund and Ultimus and in accordance with the Patriot Act and OFAC; and (vi) (A) Ultimus will reasonably cooperate with the Fund to accommodate non-material changes and adjustments to agreed upon services, maintaining reasonably adequate policies, procedures and internal controls that are consistent with the Fund’s AML program as in effect from time-to-time, (B) 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 Fund and the Fund’s AML Compliance Officer; and (C) maintain a reasonable, ongoing training program with respect to its own personnel relating to AML matters.
Appears in 3 contracts
Samples: Services Agreement (FSI Low Beta Absolute Return Fund), Services Agreement (FSI Low Beta Absolute Return Fund), Services Agreement (FSI Low Beta Absolute Return Fund)
AML Services. The Trust delegates to Ultimus Atlantic the performance of the anti-money laundering services set forth below (the “"AML Services”") with respect to investor shareholder accounts maintained by Ultimus Atlantic pursuant to the this Agreement; and subject to the terms and conditions of the this Agreement, Ultimus Atlantic accepts this delegation and agrees to perform the AML Services in accordance with the Fund’s Trust's and Ultimus’ Atlantic's AML program and reasonably to cooperate with the Fund Trust's AML Officer compliance officer (the "AML Compliance Officer") in the performance of that person’s 's responsibilities. Notwithstanding this delegation, the Fund 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.
(ia) Verify investor 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;
(iib) Monitor investor 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 Fund Trust and UltimusAtlantic;
(iiic) 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 investor shareholder information upon changes to such databases;
(ivd) Follow the Fund’s 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 Ultimus Atlantic accept a corporate third party check;
(ve) Place holds on transactions in investor shareholder accounts or freeze investor shareholder accounts, as provided in the AML programs of the Fund Trust and Ultimus Atlantic and in accordance with the Patriot Act and OFAC; and;
(vii) (A) Ultimus Atlantic will reasonably cooperate with the Fund 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 Fund’s Trust's AML program as in effect from time-to-time, (Bii) 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 Fund Trust and the Fund’s Trust's AML Compliance Officer; and (Ciii) maintain a reasonable, ongoing training program with respect to its own personnel relating to AML matters.
Appears in 3 contracts
Samples: Transfer Agency Services Agreement (Gallery Trust), Transfer Agency Services Agreement (Gallery Trust), Transfer Agency Services Agreement (Advisors' Inner Circle Fund III)
AML Services. The Trust delegates to Ultimus Atlantic the performance of the anti-money laundering services set forth below (the “AML Services”) with respect to investor shareholder accounts maintained by Ultimus Atlantic pursuant to the this Agreement; and subject to the terms and conditions of the this Agreement, Ultimus Atlantic accepts this delegation and agrees to perform the AML Services in accordance with the FundTrust’s and Ultimus’ Atlantic’s AML program and reasonably to cooperate with the Fund Trust’s AML Officer compliance officer (the “AML Compliance Officer”) in the performance of that person’s responsibilities. Notwithstanding this delegation, the Fund 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.
(ia) Verify investor 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;
(iib) Monitor investor 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 Fund Trust and UltimusAtlantic;
(iiic) 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 investor shareholder information upon changes to such databases;
(ivd) Follow the FundTrust’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 Ultimus Atlantic accept a corporate third party check;
(ve) Place holds on transactions in investor shareholder accounts or freeze investor shareholder accounts, as provided in the AML programs of the Fund Trust and Ultimus Atlantic and in accordance with the Patriot Act and OFAC; and;
(vif) (Ai) Ultimus Atlantic will reasonably cooperate with the Fund 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 Fund’s Trust's AML program as in effect from time-to-time, (Bii) 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 Fund Trust and the FundTrust’s AML Compliance Officer; and (Ciii) maintain a reasonable, ongoing training program with respect to its own personnel relating to AML matters.
Appears in 2 contracts
Samples: Transfer Agency Services Agreement (Catholic Responsible Investments Funds), Transfer Agency Services Agreement (Advisors' Inner Circle Fund III)
AML Services. The Trust delegates to Ultimus the performance (a) As agent of the anti-money laundering services set forth below Fund, perform the AML Services listed in this section 5 with respect to security holder accounts maintained by Atlantic pursuant to the Agreement and in accordance with the Fund AML Program and Atlantic’s AML program:
(b) Reasonably cooperate with the Fund’s AML compliance officer (the “AML ServicesCompliance Officer”) with respect to investor accounts maintained by Ultimus pursuant to the Agreement; and subject to the terms and conditions of the Agreement, Ultimus accepts this delegation and agrees to perform the AML Services in accordance with the Fund’s and Ultimus’ AML program and reasonably to cooperate with the Fund AML Officer in the performance of that person’s responsibilities. Notwithstanding this delegation, the Fund 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.
(ic) Verify investor security holder 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;.
(iid) Monitor investor security holder 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 Fund and Ultimus;Atlantic.
(iiie) 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 authoritiesLaw, including review of such investor security holder information upon changes to such databases;.
(ivf) Follow the Fund’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 Ultimus Atlantic accept a corporate third party check;.
(vg) Place holds on transactions in investor security holder accounts or freeze investor security holder accounts, as provided in the Fund AML programs of the Fund Program and Ultimus Atlantic AML Program and in accordance with the Patriot Act and OFAC; andOFAC regulations.
(vii) (A) Ultimus will reasonably cooperate with the Fund to accommodate non-material changes and adjustments to agreed upon services, maintaining maintain reasonably adequate policies, procedures and internal controls that are consistent with the Fund’s Fund AML program as in effect from time-to-timeProgram, (Bii) conduct (or have a third party conduct) an independent review of its Atlantic’s AML Program at least annually and provide the report of such independent review to the Fund and the Fund’s AML Compliance Officer; and (Ciii) maintain a reasonable, ongoing training program with respect to its own personnel relating to AML matters.
(i) Review all new and existing accounts against lists provided by the Financial Crimes Enforcement Network, a bureau of the U.S. Department of the Treasury (“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.
(j) Furnish the Fund its written program concerning the AML services rendered by Atlantic to its various clients and notify the Fund of any changes to the Atlantic AML Program that individually or in the aggregate would materially impact the Fund AML Program.
(k) Make its relevant personnel available to meet or speak with the Board concerning the AML Services at such intervals as may be reasonably necessary or appropriate.
(l) Provide the Fund with any reports received by Atlantic from any government agency or applicable industry self-regulatory organization pertaining to the Atlantic AML Program or the Fund AML Program. The Fund authorizes Atlantic to take such actions in the performance of the AML Services as Atlantic deems appropriate and consistent with the Fund’s AML program and applicable AML Law.
Appears in 1 contract
Samples: Services Agreement (Pine Grove Alternative Institutional Fund)
AML Services. The Trust delegates to Ultimus Atlantic the performance of the anti-money laundering services set forth below (the “AML Services”) with respect to investor accounts maintained by Ultimus Atlantic pursuant to the Agreement; and subject to the terms and conditions of the Agreement, Ultimus Atlantic accepts this delegation and agrees to perform the AML Services in accordance with the Fund’s and Ultimus’ Atlantic’s AML program and reasonably to cooperate with the Fund Fund’s AML Officer compliance officer (the “AML Compliance Officer”) in the performance of that person’s responsibilities. Notwithstanding this delegation, the Fund 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.
(ia) Verify investor 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;
(iib) Monitor investor 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 Fund and UltimusAtlantic;
(iiic) 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 investor information upon changes to such databases;
(ivd) Follow the Fund’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 Ultimus Atlantic accept a corporate third party check;
(ve) Place holds on transactions in investor accounts or freeze investor accounts, as provided in the AML programs of the Fund and Ultimus Atlantic and in accordance with the Patriot Act and OFAC; and
(vif) (Ai) Ultimus Atlantic will reasonably cooperate with the Fund to accommodate non-material changes and adjustments to agreed upon services, maintaining reasonably adequate policies, procedures and internal controls that are consistent with the Fund’s AML program as in effect from time-to-time, (Bii) 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 Fund and the Fund’s AML Compliance Officer; and (Ciii) maintain a reasonable, ongoing training program with respect to its own personnel relating to AML matters.
Appears in 1 contract
Samples: Closed End Fund Services Agreement (FSI Low Beta Absolute Return Fund)