Common use of Anti-Money Laundering Procedures Clause in Contracts

Anti-Money Laundering Procedures. (a) The Transfer Agent shall implement and operate the parts of the Funds’ policies and procedures relating to compliance with United States Federal anti-money laundering (“AML”) laws and applicable investor activity, including the Bank Secrecy Act and the USA PATRIOT Act and perform reasonable actions necessary to help the Funds be in compliance with such laws. In this regard, the Transfer Agent shall: (i) establish and implement written internal policies, procedures and controls reasonably designed to help prevent the Funds from being used to launder money or finance terrorist activities; (ii) provide for independent testing, by an employee who is not responsible for the operation of the Transfer Agent’s AML program or by an outside party, for compliance with the Transfer Agent’s established policies and procedures; (iii) designate a person or persons responsible for implementing and monitoring the operation and internal controls of the Transfer Agent’s AML program; (iv) provide ongoing training of Transfer Agent personnel relating to the prevention of money-laundering activities; and (v) provide periodic reports to the Funds relating to the services performed on their behalf under the Transfer Agent’s AML program. (b) Upon the reasonable request of the Funds, the Transfer Agent shall provide to the Funds (it being understood all such information is to be considered confidential and treated as such and afforded all protections provided to confidential information under this agreement): (i) a copy of the Transfer Agent’s written AML policies and procedures, and any amendments thereto; (ii) at the option of the Transfer Agent, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; (iii) a summary of the AML training provided for appropriate personnel; (iv) a list of individuals responsible for implementing and monitoring the Transfer Agent’s AML program; (v) a report summarizing actions taken concerning the Funds under the Transfer Agent’s AML program,; and (vi) to the extent permitted by law, information relating to any suspicious activities concerning the Funds that is required to be or may be voluntarily reported on a suspicious activity report (“SAR”). (c) The Transfer Agent agrees to permit inspections relating to its AML program by U.S. Federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to its AML program as such examiners shall reasonably request.

Anti-Money Laundering Procedures. (a) The Transfer Agent shall implement and operate perform all reasonable actions necessary to help the parts of the Funds’ policies and procedures relating to Funds be in compliance with United States Federal anti-money laundering (“"AML”") laws and applicable to investor activity, including the Bank Secrecy Act and the USA PATRIOT Act and perform reasonable actions necessary to help the Funds be in compliance with such lawsAct. In this regard, the Transfer Agent shall: (i) establish and implement written internal policies, procedures and controls reasonably designed to help prevent the Funds from being used to launder money or finance terrorist activities; (ii) provide for independent testing, by an employee who is not responsible for the operation of the Transfer Agent’s 's AML program or by an outside party, for compliance with the Transfer Agent’s 's established policies and procedures; (iii) designate a person or persons responsible for implementing and monitoring the operation and internal controls of the Transfer Agent’s 's AML program; (iv) provide ongoing training of Transfer Agent personnel relating to the prevention of money-laundering activities; and (v) provide periodic reports to the Funds relating to the services performed on their behalf under the Transfer Agent’s 's AML program. (b) Upon the reasonable request of the Funds, the Transfer Agent shall provide to the Funds (it being understood all such information is to be considered confidential and treated as such and afforded all protections provided to confidential information under this agreement): (i) a copy of the Transfer Agent’s 's written AML policies and procedures, and any amendments thereto; (ii) at the option of the Transfer Agent, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; (iii) a summary of the AML training provided for appropriate personnel; (iv) information relating to due diligence performed with respect to correspondent accounts for non-U.S. financial institutions maintained by the Transfer Agent on behalf of the Funds; (v) a list of individuals responsible for implementing and monitoring the Transfer Agent’s 's AML program; (vvi) a report summarizing describing actions taken concerning the Funds under the Transfer Agent’s 's AML program,, including information relating to the treatment of any cash received by the Transfer Agent for investment in the Funds; and (vivii) to the extent permitted by law, information relating to any suspicious activities concerning the Funds that is required to be or may be voluntarily reported on a suspicious activity report (“"SAR”"). (c) The Transfer Agent agrees to permit inspections relating to its AML program by U.S. Federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to its AML program as such examiners shall reasonably request.. Exhibit 1 to Schedule C SUMMARY OF SERVICES The services to be performed by the Transfer Agent or its agent shall include the following: A. DAILY RECORDS Maintain daily the following information with respect to each Shareholder account as received: . Name and Address (Zip Code) . Class of Shares . Taxpayer Identification Number . Balance of Shares held by Agent . Beneficial owner code: i.e., male, female, joint tenant, etc. . Dividend code (reinvestment) . Number of Shares held in certificate form

Anti-Money Laundering Procedures. (a) The Transfer Agent shall implement and operate perform reasonable actions necessary to help the parts of the Funds’ policies and procedures relating to Funds be in compliance with United States Federal anti-money laundering (“"AML”") laws and applicable to investor activity, including the Bank Secrecy Act and the USA PATRIOT Act and perform reasonable actions necessary to help the Funds be in compliance with such laws. as follows: In this regard, the Transfer Agent shall: (i) establish and implement written internal policies, procedures and controls reasonably designed to help prevent the Funds from being used to launder money or finance terrorist activities; (ii) provide for independent testing, by an employee who is not responsible for the operation of the Transfer Agent’s 's AML program or by an outside party, for compliance with the Transfer Agent’s 's established policies and procedures; (iii) designate a person or persons responsible for implementing and monitoring the operation and internal controls of the Transfer Agent’s 's AML program; (iv) provide ongoing training of Transfer Agent personnel relating to the prevention of money-laundering activities; and (v) provide periodic reports to the Funds relating to the services performed on their behalf under the Transfer Agent’s 's AML program. (b) Upon the reasonable request of the Funds, the Transfer Agent shall provide to the Funds (it being understood all such information is to be considered confidential and treated as such and afforded all protections provided to confidential information under this agreement): (i) a copy of the Transfer Agent’s 's written AML policies and procedures, and any amendments thereto; (ii) at the option of the Transfer Agent, a copy of a written assessment or report prepared by the party performing the independent testing for compliance, or a summary thereof, or a certification that the findings of the independent party are satisfactory; (iii) a summary of the AML training provided for appropriate personnel; (iv) a list of individuals responsible for implementing and monitoring the Transfer Agent’s 's AML program; (v) a report summarizing actions taken concerning the Funds under the Transfer Agent’s 's AML program,; and (vi) to the extent permitted by law, information relating to any suspicious activities concerning the Funds that is required to be or may be voluntarily reported on a suspicious activity report (“"SAR”"). (c) The Transfer Agent agrees to permit inspections relating to its AML program by U.S. Federal departments or regulatory agencies with appropriate jurisdiction and to make available to examiners from such departments or regulatory agencies such information and records relating to its AML program as such examiners shall reasonably request.