AML Services5. 3.1 Consistent with the Transfer Agency services provided and with respect to the ownership of Shares in the Funds for which the Transfer Agent maintains the applicable shareholder information, and as described in the AML Procedures SS&C shall provide the following denoted AML Services: SERVICE Performed (X) Customer Identification Program Services including Beneficial Ownership -USA PATRIOT Act (USAPA) Section 326 X Special Measures Imposed by the Secretary of the Treasury Processing – USAPA Section 311 X Suspicious Activity Monitoring (Transaction Monitoring) - USAPA Section 356 X Recordkeeping obligations imposed by AML/BSA; OFAC X Sanctions Program Screening (OFAC; OSFI; EU; FATF) X Mandatory Information Sharing with Law Enforcement - USAPA Section 314(a) X Due Diligence for Correspondent Accounts - USAPA Section 312 X Enhanced Due Diligence for Certain Foreign Bank Correspondent Accounts - USAPA Section 312 X Suspicious Activity Report (“SAR”) Preparation & Filing6 and 7 X PEP Screening X 5 The persons, account holders, accounts and transaction activity subject to review are subject to certain standard exclusions as set forth in written procedures provided to the Fund and that may be modified from time to time. 6 Reporting of known or suspected violations of law or suspicious activity observed by financial institutions related to criminal behavior, such as money laundering, fraud, the financing of terrorism, etc. 7 Promptly following the filing of each SAR, the Transfer Agent shall send to Fund (or its designee) at certain email addresses provided from time to time by the Fund, a copy of the SAR and evidence of filing; material in support of the SAR is available upon request.
AML Services5. 3.1 Consistent with the Transfer Agency services provided and with respect to the ownership of Shares in the Funds for which the Transfer Agent maintains the applicable Shareholder information, and as described in the AML Procedures SS&C shall provide the following denoted AML Services: SERVICE Performed (X) Customer Identification Program Services including Beneficial Ownership - USA PATRIOT Act (USAPA) Section 326 X Special Measures Imposed by the Secretary of the Treasury Processing – USAPA Section 311 X Suspicious Activity Monitoring (Transaction Monitoring) - USAPA Section 356 X Recordkeeping obligations imposed by AML/BSA; OFAC X Sanctions Program Screening (OFAC; OSFI; EU; FATF) X Mandatory Information Sharing with Law Enforcement - USAPA Section 314(a) X Due Diligence for Correspondent Accounts - USAPA Section 312 X Enhanced Due Diligence for Certain Foreign Bank Correspondent Accounts - USAPA Section 312 X Suspicious Activity Report (“SAR”) Preparation & Filing6 and 7 X PEP Screening X 5 The persons, account holders, accounts and transaction activity subject to review are subject to certain standard exclusions as set forth in written procedures provided to the Fund and that may be modified from time to time.
AML Services5. 3.1 Consistent with the Transfer Agency services provided and with respect to the ownership of Shares in the Funds for which SS&C maintains the applicable Shareholder information, and as described in the AML Procedures SS&C shall provide the following denoted AML Services: Service Performed (X) Customer Identification Program Services including Beneficial Ownership -USA PATRIOT Act (USAPA) Section 326 X Special Measures Imposed by the Secretary of the Treasury Processing – USAPA Section 311 X 1 Generally the Bank Secrecy Act and USA PATRIOT Act of 2001, as amended 2 Prohibited transactions are trade or financial transactions and other dealings in which U.S. persons may not engage unless authorized by OFAC or expressly exempted by statute. Because each sanction program is based on different foreign policy and national security goals, prohibitions may vary between programs. 3 As part of its enforcement efforts, OFAC publishes a list of individuals and companies owned or controlled by, or acting for or on behalf of, targeted countries. It also lists individuals, groups, and entities, such as terrorists and narcotics traffickers designated under programs that are not country-specific. Collectively, such individuals and companies are called “Specially Designated Nationals” or “SDNs.” Their assets are blocked and U.S. persons are generally prohibited from dealing with them. 4 Modifications deemed administrative, ministerial or immaterial require no notice. Notice precedes modifications deemed material. 5 The persons, account holders, accounts and transaction activity subject to review are subject to certain standard exclusions as set forth in written procedures provided to the Funds and that may be modified from time to time. Suspicious Activity Monitoring (Transaction Monitoring) - USAPA Section 356 X Recordkeeping obligations imposed by AML/BSA; OFAC X Sanctions Program Screening (OFAC; OSFI; EU;FATF) X Due Diligence for Correspondent Accounts - USAPA Section 312 X Enhanced Due Diligence for Certain Foreign Bank Correspondent Accounts - USAPA Section 312 X Suspicious Activity Report (“SAR”) Preparation & Filing6 and 7 X PEP Screening X SS&C will permit the Fund and, subject to an NDA with SS&C, its duly authorized agents, as well as duly authorized federal examiners to make periodic inspections of its operations as such would involve a Fund to obtain, inter alia, information and records relating to SS&C’s performance of its Compliance + Program or Identity The...
AML Services5
