Common use of Anti-Money Laundering Compliance Program Clause in Contracts

Anti-Money Laundering Compliance Program. The parties hereto acknowledge and agree that insurance agencies and securities broker-dealers are subject to certain regulations set forth under the Bank Secrecy Act (the "BSA") and [SEC]352 of the USA PATRIOT Act (the "PATRIOT Act") related to adopting and implementing an anti-money laundering compliance program ("AML Program"). Each party hereto represents and warrants that it has effectively implemented a written AML Program, which includes at a minimum: a) incorporating policies, procedures and internal controls reasonably designed to assure compliance with BSA and the PATRIOT Act; b) designating a compliance officer responsible for day-to-day compliance with the BSA and the AML Program; c) providing education and/or training of Representatives and other appropriate personnel concerning their responsibilities under the AML Program, including training in the detection of suspicious transactions; and d) providing for independent review to monitor and maintain an adequate AML Program. The parties agree that CUNA Mutual and CUNA Brokerage have the right, upon reasonable request, to examine the description of the training provided to Representatives to ensure that the AML Program of General Agent and/or Broker-Dealer provides adequate training for Representatives. In the event General Agent and/or Broker-Dealer or Representatives become aware of circumstances related to a customer that may be suspicious, General Agent, Broker-Dealer or Representative, as the case may be, agrees to promptly notify the Anti-Money Laundering Officer at CUNA Mutual regarding such suspicious activity. Furthermore, the parties represent and warrant that each has adopted and will continue to execute a customer identification program (the "CIP") meeting the requirements under the PATRIOT Act. The parties agree that CUNA Mutual and CUNA Brokerage have the right, upon reasonable request, to examine the description of the CIP that General Agent and/or Broker-Dealer has adopted and implemented.

Anti-Money Laundering Compliance Program. The parties hereto acknowledge and agree that insurance agencies and securities broker-dealers are subject to certain regulations set forth under the Bank Secrecy Act (the "“BSA"”) and [SEC]352 §352 of the USA PATRIOT Act (the "“PATRIOT Act"”) related to adopting and implementing an anti-money laundering compliance program ("“AML Program"”). Each party hereto represents and warrants that it has effectively implemented a written AML Program. General Agent and Broker-Dealer each hereby represents and warrants that its AML program includes, which includes at a minimum: a) incorporating policies, procedures and internal controls reasonably designed to assure compliance with BSA and the PATRIOT Act; b) designating a compliance officer responsible for day-to-day compliance with the BSA and the AML Program; c) providing education and/or training of Representatives and other appropriate personnel concerning their responsibilities under the AML Program, including training in the detection of suspicious transactions; and d) providing for independent review to monitor and maintain an adequate AML Program. The parties agree that CUNA Mutual and CUNA Brokerage have the right, upon reasonable request, to examine the description of the training provided to Representatives to ensure that the AML Program of General Agent and/or Broker-Dealer provides adequate training for Representatives. In the event General Agent and/or Broker-Dealer or Representatives become aware of circumstances related to a customer that may be suspicious, General Agent, Broker-Dealer or Representative, as the case may be, agrees to promptly notify the Anti-Money Laundering Officer at CUNA Mutual regarding such suspicious activity. Furthermore, the parties represent and warrant that each has adopted and will continue to execute a customer identification program (the "“CIP"”) meeting the requirements under the PATRIOT Act. The parties agree that CUNA Mutual and CUNA Brokerage have the right, upon reasonable request, to examine the description of the CIP that General Agent and/or Broker-Dealer has adopted and implemented. The parties agree that CUNA Mutual and CUNA Brokerage may require an annual certification relating to General Agent and/or Broker-Dealer’s AML and CIP programs.

Anti-Money Laundering Compliance Program. The parties hereto acknowledge Dealer acknowledges that investors who purchase Shares through Dealer are “customers” of Dealer and agree not the Dealer Manager. The Dealer hereby represents that insurance agencies it has complied and securities broker-dealers are subject to certain regulations set forth under the Bank Secrecy Act (the "BSA") and [SEC]352 will comply with Section 326 of the USA PATRIOT Patriot Act of 2001 and the implementing rules and regulations promulgated thereunder (the "PATRIOT “Patriot Act"”) related to adopting in connection with broker dealers’ anti-money laundering obligations (the “AML Rules”). The Dealer hereby represents that it has adopted and implementing an implemented, and will maintain a written anti-money laundering compliance program ("“AML Program")”) including, without limitation, anti-money laundering policies and procedures relating to customer identification as required by the Patriot Act and the implementing rules and regulations promulgated thereunder. Each party hereto represents In accordance with these applicable laws and warrants that it has effectively implemented a written regulations and its AML Program, which includes the Dealer agrees to verify the identity of its new customers; to maintain customer records; to check the names of new customers against government watch lists, including the Office of Foreign Asset Control’s (OFAC) list of Specially Designated Nationals and Blocked Persons. Additionally, Dealer will monitor account activity to identify patterns of unusual size or volume, geographic factors and any other “red flags” described in the Patriot Act as potential signals of money laundering or terrorist financing. The Dealer will submit to the Financial Crimes Enforcement Network any required suspicious activity reports about such activity and further will disclose such activity to applicable federal and state law enforcement when required by law. Upon request by the Dealer Manager at a minimum: any time, the Dealer hereby agrees to furnish (a) incorporating policiesa copy of its AML Program to the Dealer Manager for review, procedures and internal controls reasonably designed to assure compliance with BSA and the PATRIOT Act; (b) designating a compliance officer responsible for day-to-day compliance copy of the findings and any remedial actions taken in connection with the BSA and the AML Program; c) providing education and/or training Dealer’s most recent independent testing of Representatives and other appropriate personnel concerning their responsibilities under the AML Program, including training in the detection of suspicious transactions; and d) providing for independent review to monitor and maintain an adequate its AML Program. The parties agree that CUNA Mutual Dealer further understands that, while the Dealer Manager is required to establish and CUNA Brokerage have the right, upon reasonable request, to examine the description of the training provided to Representatives to ensure that implement an AML Program in accordance with the AML Rules, the Dealer cannot rely on the Dealer Manager’s AML Program for purposes of General Agent and/or Broker-Dealer’s compliance with the AML Rules. The Dealer provides adequate training for Representatives. In agrees to notify the Dealer Manager immediately if the Dealer is subject to a FINRA disclosure event General Agent and/or Broker-Dealer or Representatives become aware of circumstances fine from FINRA related to a customer that may be suspicious, General Agent, Broker-Dealer or Representative, as the case may be, agrees to promptly notify the Anti-Money Laundering Officer at CUNA Mutual regarding such suspicious activity. Furthermore, the parties represent and warrant that each has adopted and will continue to execute a customer identification program (the "CIP") meeting the requirements under the PATRIOT Act. The parties agree that CUNA Mutual and CUNA Brokerage have the right, upon reasonable request, to examine the description of the CIP that General Agent and/or Broker-Dealer has adopted and implementedits AML Program.

Anti-Money Laundering Compliance Program. The parties hereto acknowledge and agree that insurance agencies and securities broker-dealers are subject to certain regulations set forth under the Bank Secrecy Act (the "BSA") and [SEC]352 of the USA PATRIOT Act (the "PATRIOT Act") related to adopting and implementing an anti-money laundering compliance program ("AML Program"). Each party hereto represents and warrants that it has effectively implemented a written AML Program, which includes at a minimum: a) incorporating policies, procedures and internal controls reasonably designed to assure compliance with BSA and the PATRIOT Act; b) designating a compliance officer responsible for day-to-day compliance with the BSA and the AML Program; c) providing education and/or training of Representatives and other appropriate personnel concerning their responsibilities under the AML Program, including training in the detection of suspicious transactions; and d) providing for independent review to monitor and maintain an adequate AML Program. The parties agree that CUNA Mutual and CUNA Brokerage have the right, upon reasonable request, to examine the description of the training provided to Representatives to ensure that the AML Program of General Agent and/or Broker-Dealer provides adequate training for Representatives. In the event General Agent and/or Broker-Dealer or Representatives become aware of circumstances related to a customer that may be suspicious, General Agent, Broker-Dealer or Representative, as the case may be, agrees to promptly notify the Anti-Money Laundering Officer at CUNA Mutual regarding such suspicious activity. Furthermore, the parties represent and warrant that each has adopted and will continue to execute a customer identification program (the "CIP") meeting the requirements under the PATRIOT Act. The parties agree that CUNA Mutual and CUNA Brokerage have the right, upon reasonable request, to examine the description of the CIP that General Agent and/or Broker-Dealer has adopted and implemented.

Anti-Money Laundering Compliance Program. The parties hereto acknowledge and agree that insurance agencies and securities broker-dealers are subject to certain regulations set forth under the Bank Secrecy Act (the "BSA") and [SEC]352 of the USA PATRIOT Act (the "PATRIOT Act") related to adopting and implementing an anti-money laundering compliance program ("AML Program"). Each party hereto represents and warrants that it has effectively implemented a written AML Program, which includes at a minimum: a) incorporating policies, procedures and internal controls reasonably designed to assure compliance with BSA and the PATRIOT Act; b) designating a compliance officer responsible for day-to-day compliance with the BSA and the AML Program; c) providing education and/or training of Representatives and other appropriate personnel concerning their responsibilities under the AML Program, including training in the detection of suspicious transactions; and d) providing for independent review to monitor and maintain an adequate AML Program. The parties agree that CUNA Mutual MLIC and CUNA Brokerage have the right, upon reasonable request, to examine the description of the training provided to Representatives to ensure that the AML Program of General Agent and/or Broker-Dealer provides adequate training for Representatives. In the event General Agent and/or Broker-Dealer or Representatives become aware of circumstances related to a customer that may be suspicious, General Agent, Broker-Dealer or Representative, as the case may be, agrees to promptly notify the Anti-Money Laundering Officer at CUNA Mutual MLIC regarding such suspicious activity. Furthermore, the parties represent and warrant that each has adopted and will continue to execute a customer identification program (the "CIP") meeting the requirements under the PATRIOT Act. The parties agree that CUNA Mutual MLIC and CUNA Brokerage have the right, upon reasonable request, to examine the description of the CIP that General Agent and/or Broker-Dealer has adopted and implemented.