Common use of Anti-Money Laundering; Customer Identification Program FinCEN Requests Clause in Contracts

Anti-Money Laundering; Customer Identification Program FinCEN Requests. (a) The Transfer Agent has adopted and will maintain compliance program that is reasonably designed to promote the detection and reporting of potential money laundering activity and identity theft by monitoring shareholder activity as well as adopting written procedures for verifying a customer’s identity (collectively, the “AML Program”). The AML Program is designed to facilitate registered investment company compliance with applicable money laundering and client identity theft laws, rules and regulations including but not limited to those promulgated by (i) the United States Treasury and Financial Crimes Enforcement Network (“FinCEN”) under the Bank Secrecy Act; (ii) the Office of Foreign Asset Control (“OFAC”); and (iii) the United States Securities & Exchange Commission.

Anti-Money Laundering; Customer Identification Program FinCEN Requests. (a) The Transfer Agent ALPS has adopted and will maintain a compliance program that is reasonably designed to promote the detection and reporting of potential money laundering activity and identity theft by monitoring shareholder activity as well as adopting written procedures for verifying a customer’s identity (collectively, the “AML Program”). The AML Program is designed to facilitate registered investment company compliance with applicable money laundering and client identity theft laws, rules and regulations including but not limited to those promulgated by (i) the United States Treasury and Financial Crimes Enforcement Network (“FinCEN”) under the Bank Secrecy Act; (ii) the Office of Foreign Asset Control (“OFAC”); and (iii) the United States Securities & Exchange Commission.