Common use of Anti-Money Laundering and CIP Clause in Contracts

Anti-Money Laundering and CIP. EM has been or will be provided with a copy of RB’s compliance document titled “ANTI-MONEY LAUNDERING REQUIREMENTS” (the “AML Requirements”), attached as Exhibit E. EM will comply with the AML Requirements as the same are amended by RB from time to time. Such obligation shall include, but not be limited to the following: (i) EM shall review customer information regarding each such Applicant, and shall be responsible for ensuring that each such Borrower meets the requirements of RB’s Customer Identification Program (“CIP”), as required by Applicable Law and the AML Requirements. (ii) EM shall comply with all Office of Foreign Assets Control (“OFAC”) regulations, including but not limited to: (1) ensuring that all Applicants are regularly screened through a screening system implemented to comply with OFAC regulations and the AML Requirements; and (2) complying with all OFAC and RB directives regarding the prohibition or rejection of unlicensed trade and financial transactions with OFAC specified countries, entities and individuals. (iii) EM shall report any suspicious activity to RB and in accordance with applicable Law and the AML Requirements. (iv) EM shall make all training records available for review by RB or a Governmental Authority."

Anti-Money Laundering and CIP. EM has been or will be provided with a copy of RB’s compliance document titled “ANTI-MONEY LAUNDERING REQUIREMENTS” (the “AML Requirements”), attached as Exhibit E. EM will comply with the AML Requirements as the same are amended by RB from time to time. Such obligation shall include, but not be limited to the following: (i) EM shall review customer information regarding each such Applicant, and shall be responsible for ensuring that each such Borrower meets the requirements of RB’s Customer Identification Program (“CIP”), as required by Applicable Law and the AML Requirements. (ii) EM shall comply with all Office of Foreign Assets Control (“OFAC”) regulations, including but not limited to:: [****] = CERTAIN CONFIDENTIAL INFORMATION CONTAINED IN THIS DOCUMENT, MARKED BY BRACKETS, HAS BEEN OMITTED AND FILED SEPARATELY WITH THE SECURITIES AND EXCHANGE COMMISSION PURSUANT TO RULE 24B-2 OF THE SECURITIES EXCHANGE ACT OF 1934, AS AMENDED. (1) ensuring that all Applicants are regularly screened through a screening system implemented to comply with OFAC regulations and the AML Requirements; and (2) complying with all OFAC and RB directives regarding the prohibition or rejection of unlicensed trade and financial transactions with OFAC specified countries, entities and individuals. (iii) EM shall report any suspicious activity to RB and in accordance with applicable Law and the AML Requirements. (iv) EM shall make all training records available for review by RB or a Governmental Authority."

Anti-Money Laundering and CIP. EM E@W has been or will be provided with a copy of RBBank’s compliance document titled “ANTI-MONEY LAUNDERING REQUIREMENTS” (the “AML Requirements”), attached as Exhibit E. EM E@W will comply with the AML Requirements as the same are amended by RB Bank from time to time. Such obligation shall include, but not be limited to the following: (i) EM E@W shall review customer information regarding each such Applicant, and shall be responsible for ensuring that each such Borrower Cardholder meets the requirements of RBBank’s Customer Identification Program (“CIP”), as required by Applicable Law and the AML Requirements. [****] = CERTAIN CONFIDENTIAL INFORMATION CONTAINED IN THIS DOCUMENT, MARKED BY BRACKETS, HAS BEEN OMITTED AND FILED SEPARATELY WITH THE SECURITIES AND EXCHANGE COMMISSION PURSUANT TO RULE 24B-2 OF THE SECURITIES EXCHANGE ACT OF 1934, AS AMENDED. (ii) EM E@W shall comply with all Office of Foreign Assets Control (“OFAC”) regulations, including but not limited to: (1) ensuring that all Applicants are regularly screened through a screening system implemented to comply with OFAC regulations and the AML Requirements; , and (2) complying with all OFAC and RB directives regarding the prohibition or rejection of unlicensed trade and financial transactions with OFAC specified countries, entities and individuals. (iii) EM E@W shall report any suspicious activity to RB and in accordance with applicable Law and the AML Requirements. (iv) EM E@W shall make all training records available for review by RB Bank or a Governmental Authority."

Anti-Money Laundering and CIP. EM E@W has been or will be provided with a copy of RBBank’s compliance document titled “ANTI-MONEY LAUNDERING REQUIREMENTS” (the “AML Requirements”), attached as Exhibit E. EM E@W will comply with the AML Requirements as the same are amended by RB Bank from time to time. Such obligation shall include, but not be limited to the following: (i) EM E@W shall review customer information regarding each such Applicant, and shall be responsible for ensuring that each such Borrower Cardholder meets the requirements of RBBank’s Customer Identification Program (“CIP”), as required by Applicable Law and the AML Requirements. [****] = CERTAIN CONFIDENTIAL INFORMATION CONTAINED IN THIS DOCUMENT, MARKED BY BRACKETS, HAS BEEN OMITTED AND FILED SEPARATELY WITH THE SECURITIES AND EXCHANGE COMMISSION PURSUANT TO RULE 406 OF THE SECURITIES ACT OF 1933, AS AMENDED. (ii) EM E@W shall comply with all Office of Foreign Assets Control (“OFAC”) regulations, including but not limited to: (1) ensuring that all Applicants are regularly screened through a screening system implemented to comply with OFAC regulations and the AML Requirements; , and (2) complying with all OFAC and RB directives regarding the prohibition or rejection of unlicensed trade and financial transactions with OFAC specified countries, entities and individuals. (iii) EM E@W shall report any suspicious activity to RB and in accordance with applicable Law and the AML Requirements. (iv) EM E@W shall make all training records available for review by RB Bank or a Governmental Authority."