Common use of Anti-Money Laundering Services Clause in Contracts

Anti-Money Laundering Services. (A) ADOPTION OF ANTI-MONEY LAUNDERING PROGRAM AND DELEGATION OF SERVICES TO THE ADMINISTRATOR. The Trust hereby delegates to the Administrator the performance, on behalf of the Trust, of the services set forth in Schedule C hereto (the "AML Services") with respect to all Shareholder accounts maintained by the Administrator pursuant to this Agreement. The Administrator accepts this delegation and agrees to perform or supervise the performance of the AML Services in accordance with the Trust's AML Program and the Administrator's anti-money laundering program and to cooperate with the Trust's AML Compliance Officer in the performance of its responsibilities hereunder. The Administrator may employ SIMC and may sub-contract with other affiliated or non-affiliated third parties to perform all or part of the services to be performed by the Administrator under this Article 4; provided, however, that the Administrator shall remain responsible to the Trust for the acts and omissions of SIMC and such sub-contracted parties. The Administrator will certify annually to the Trust that it has implemented the Trust's AML Program, and that the Administrator (or its agent) will perform the specific requirements of the Trust's AML Program delegated to the Administrator. Notwithstanding this delegation, the Trust shall maintain full responsibility for ensuring that its AML Program is and continues to be reasonably designed to ensure compliance with the USA Patriot Act and Bank Secrecy Act (collectively, the "AML Acts") and any regulation adopted under the AML Acts (the "Applicable AML Laws"). The Administrator shall maintain policies, procedures and internal controls that are consistent with the Trust's AML Program and the requirement that the Trust employ procedures reasonably designed to achieve compliance with the Applicable AML Laws and the Trust's AML Program. The Trust recognizes that the performance of the AML Services involves the exercise of discretion, which in certain circumstances may result in consequences to the Trust and its Shareholders (such as in the case of the reporting of suspicious activities and the freezing of Shareholders' accounts). The Trust authorizes the Administrator to take such actions in the performance of the AML Services as the Administrator deems appropriate and consistent with the Trust's AML Program and Applicable AML Laws.

Anti-Money Laundering Services. (A) ADOPTION OF ANTI-MONEY LAUNDERING PROGRAM AND DELEGATION OF SERVICES TO THE ADMINISTRATOR. The Trust hereby delegates to you, and you agree to accept the Administrator delegation of, the performance, on behalf of the Trust, of the those anti-money laundering services set forth in Schedule C hereto (the "AML Services") set forth in Exhibit B concerning those retailing broker-dealers that open accounts with respect the Trust in order to all Shareholder accounts maintained by purchase creation units of the Administrator pursuant Trust's Funds into inventory and then sell them to this Agreementthe public. The Administrator accepts this You agree to the foregoing delegation and agrees to agree that you will perform or supervise the performance of the delegated AML Services in accordance with the Trust's AML Program Program. In connection therewith, you agree to maintain policies and the Administrator's anti-money laundering program and to cooperate with the Trust's AML Compliance Officer in the performance of its responsibilities hereunder. The Administrator may employ SIMC and may sub-contract with other affiliated or non-affiliated third parties to perform all or part of the services to be performed by the Administrator under this Article 4; provided, however, that the Administrator shall remain responsible to the Trust for the acts and omissions of SIMC and such sub-contracted parties. The Administrator will certify annually to the Trust that it has implemented the Trust's AML Programprocedures, and that the Administrator (or its agent) will perform the specific requirements of the Trust's AML Program delegated to the Administrator. Notwithstanding this delegationrelated internal controls, the Trust shall maintain full responsibility for ensuring that its AML Program is and continues to be reasonably designed to ensure compliance with the USA Patriot Act and Bank Secrecy Act (collectively, the "AML Acts") and any regulation adopted under the AML Acts (the "Applicable AML Laws"). The Administrator shall maintain policies, procedures and internal controls that are consistent with the Trust's AML Program and the requirement that the Trust employ procedures reasonably designed to achieve compliance with applicable anti-money laundering laws, regulations and rules, including the Applicable requirement to have policies and procedures that can be reasonably expected to detect and cause the reporting of transactions under the Bank Secrecy Act, as amended by the USA PATRIOT Act of 2001. You also agree to keep and maintain on behalf of the Trust all books and records which the Trust and you are, or may be, required to keep and maintain pursuant to any applicable laws, regulations, and rules, including without limitation Rules 31a-1 and 31a-2 under the 1940 Act, relating to the maintenance of books and records in connection with the AML Laws services to be provided hereunder. You further agree that all such books and records shall be the property of the Trust and to make such books and records available for inspection by the Trust or by the Trust's AML Program. The Trust recognizes that regulators, including the performance of the AML Services involves the exercise of discretionSEC, which in certain circumstances may result in consequences at reasonable times and otherwise to keep confidential all books and records and other information relative to the Trust and its Shareholders shareholders consistent with the requirements of Regulation S-P. 2.1 In providing the services and assuming the obligations set forth herein, you may, contract with one or more third party service providers (such "Servicers") as you deem appropriate in the case of the reporting of suspicious activities and the freezing of Shareholders' accounts). The Trust authorizes the Administrator to take such actions in connection with the performance of your duties and obligations hereunder. Reference herein to your duties and responsibilities shall include the AML Services as duties and responsibilities of any Servicer contracted with by you to the Administrator deems appropriate extent that you shall delegate such duties and consistent with the Trust's AML Program and Applicable AML Lawsresponsibilities to such Servicer.

Anti-Money Laundering Services. (A) ADOPTION OF ANTI-MONEY LAUNDERING PROGRAM AND DELEGATION OF SERVICES TO THE ADMINISTRATOR. The Trust hereby delegates to you, and you agree to accept the Administrator delegation of, the performance, on behalf of the Trust, of those anti-money laundering services (the services “AML Services”) set forth in Schedule C hereto (Exhibit B concerning those retailing broker-dealers that open accounts with the "AML Services") with respect Trust in order to all Shareholder accounts maintained by purchase creation units of the Administrator pursuant Trust’s Funds into inventory and then sell them to this Agreementthe public. The Administrator accepts this You agree to the foregoing delegation and agrees to agree that you will perform or supervise the performance of the delegated AML Services in accordance with the Trust's AML Program and the Administrator's anti-money laundering program and to cooperate with the Trust's AML Compliance Officer in the performance of its responsibilities hereunder. The Administrator may employ SIMC and may sub-contract with other affiliated or non-affiliated third parties to perform all or part of the services to be performed by the Administrator under this Article 4; provided, however, that the Administrator shall remain responsible to the Trust for the acts and omissions of SIMC and such sub-contracted parties. The Administrator will certify annually to the Trust that it has implemented the Trust's ’s AML Program. In connection therewith, you agree to maintain policies and procedures, and that the Administrator (or its agent) will perform the specific requirements of the Trust's AML Program delegated to the Administrator. Notwithstanding this delegationrelated internal controls, the Trust shall maintain full responsibility for ensuring that its AML Program is and continues to be reasonably designed to ensure compliance with the USA Patriot Act and Bank Secrecy Act (collectively, the "AML Acts") and any regulation adopted under the AML Acts (the "Applicable AML Laws"). The Administrator shall maintain policies, procedures and internal controls that are consistent with the Trust's ’s AML Program and the requirement that the Trust employ procedures reasonably designed to achieve compliance with applicable anti-money laundering laws, regulations and rules, including the Applicable requirement to have policies and procedures that can be reasonably expected to detect and cause the reporting of transactions under the Bank Secrecy Act, as amended by the USA PATRIOT Act of 2001. You also agree to keep and maintain on behalf of the Trust all books and records which the Trust and you are, or may be, required to keep and maintain pursuant to any applicable laws, regulations, and rules, including without limitation Rules 31a-1 and 31a-2 under the 1940 Act, relating to the maintenance of books and records in connection with the AML Laws services to be provided hereunder. You further agree that all such books and records shall be the property of the Trust and to make such books and records available for inspection by the Trust or by the Trust's AML Program. The Trust recognizes that ’s regulators, including the performance of the AML Services involves the exercise of discretionSEC, which in certain circumstances may result in consequences at reasonable times and otherwise to keep confidential all books and records and other information relative to the Trust and its Shareholders shareholders consistent with the requirements of Regulation S-P. 2.1 In providing the services and assuming the obligations set forth herein, you may, contract with one or more third party service providers (such “Servicers”) as you deem appropriate in the case of the reporting of suspicious activities and the freezing of Shareholders' accounts). The Trust authorizes the Administrator to take such actions in connection with the performance of your duties and obligations hereunder. Reference herein to your duties and responsibilities shall include the AML Services as duties and responsibilities of any Servicer contracted with by you to the Administrator deems appropriate extent that you shall delegate such duties and consistent with the Trust's AML Program and Applicable AML Lawsresponsibilities to such Servicer.

Anti-Money Laundering Services. (A) ADOPTION OF ANTI-MONEY LAUNDERING PROGRAM AND DELEGATION OF SERVICES TO THE ADMINISTRATOR. The Trust hereby delegates to the Administrator the performance, on behalf As agent of the Trust, of perform the following anti-money laundering services set forth in Schedule C hereto and the related recordkeeping required by the Trust's AML Program, (the "AML Services") with respect to all Shareholder accounts maintained by the Administrator Atlantic pursuant to this Agreement. The Administrator accepts this delegation the Agreement and agrees to perform or supervise the performance of the AML Services in accordance with the Trust's and Atlantic's AML Program and the Administrator's anti-money laundering program and to program: (a) Reasonably cooperate with the Trust's AML compliance officer (the "AML Compliance Officer Officer") in the performance of its responsibilities hereunder. The Administrator may employ SIMC that person's responsibilities; (b) Verify shareholder identity upon opening new customer accounts in accordance with Sections 312 and may sub-contract with other affiliated or non-affiliated third parties to perform all or part 326 of the services USA PATRIOT Act (the "Patriot Act") and any regulations thereunder; (c) Monitor shareholder transactions and identify and report suspicious activities that are required to be performed so identified and reported, in each case consistent with the AML programs of the Trust and Atlantic; (d) Review all new accounts and registration maintenance transactions against the Office of Foreign Asset Control ("OFAC") database and other such lists or databases of trade restricted individuals or entities as may be required from time to time by applicable Law, including review of such Shareholder information upon changes to such databases; (e) Follow the Administrator under this Article 4Trust's policies with respect to the acceptance of cash equivalents and third party checks; provided, however, that unless the Administrator shall remain responsible to parties agree otherwise under no circumstance will Atlantic accept a corporate third party check; (f) Place holds on transactions in Shareholder accounts or freeze Shareholder accounts, as provided in the AML programs of the Trust for the acts and omissions of SIMC Atlantic and such sub-contracted parties. The Administrator will certify annually to the Trust that it has implemented the Trust's AML Program, and that the Administrator (or its agent) will perform the specific requirements of the Trust's AML Program delegated to the Administrator. Notwithstanding this delegation, the Trust shall maintain full responsibility for ensuring that its AML Program is and continues to be reasonably designed to ensure compliance in accordance with the USA Patriot Act and Bank Secrecy Act OFAC regulations; (collectivelyg) (i) subject to the Change Control Process, the "AML Acts") and any regulation adopted under the AML Acts (the "Applicable AML Laws"). The Administrator shall maintain reasonably adequate policies, procedures and internal controls that are consistent with the Trust's AML program as in effect from time-to-time, (ii) conduct (or have a third party conduct) an independent review of its AML Program at least annually and provide the report of such independent review to the Trust and the requirement that AML Compliance Officer; and (iii) maintain a reasonable, ongoing training program with respect to its own personnel relating to AML matters; (h) Review all new and existing accounts against lists provided by the Financial Crimes Enforcement Network, a bureau of the U.S. Department of the Treasury ("FinCEN") as set out in Section 314 of the Patriot Act and any regulations thereunder, and pursuant to Section 314, (i) report identified accounts to FinCEN, and( ii) maintain the security of information requests; (i) Furnish the Trust employ procedures reasonably designed its written program concerning AML services rendered by Atlantic to achieve compliance with its various clients and notify the Applicable Trust of any changes to its AML Laws and program that individually or in the aggregate would materially impact the Trust's AML Program. The Trust recognizes that program; (j) Make its relevant personnel available to meet or speak with the performance of Board concerning the AML Services involves the exercise of discretion, which in certain circumstances at such intervals as may result in consequences to the Trust be reasonably necessary or appropriate; and its Shareholders (such as in the case of the reporting of suspicious activities and the freezing of Shareholders' accounts). The Trust authorizes the Administrator Atlantic to take such actions in the performance of the AML Services as the Administrator Atlantic deems appropriate and consistent with the Trust's AML Program program and Applicable applicable AML LawsLaw.

Anti-Money Laundering Services. (A) ADOPTION OF ANTI-MONEY LAUNDERING PROGRAM AND DELEGATION OF SERVICES TO THE ADMINISTRATOR1. The Trust hereby delegates has adopted policies and procedures designed to prevent and detect money laundering which comply with the Administrator the performance, on behalf anti-money laundering requirements of the Trust, of USA PATRIOT Act and the services set forth in Schedule C hereto rules and regulations promulgated thereunder (the "AML Services"Program) with respect to all Shareholder accounts maintained by The Trust hereby directs the Administrator pursuant to this Agreement. The Administrator accepts this delegation and agrees Transfer Agent to perform or supervise the performance those aspects of the AML Services in accordance with the Trust's AML Program and the Administrator's anti-money laundering program and to cooperate with the Trust's AML Compliance Officer in the performance of its responsibilities hereundersuch other duties that are set forth on Exhibit H hereto. The Administrator duties set forth on Exhibit H may employ SIMC be amended, from time to time, by mutual agreement of the Trust and may sub-contract with other affiliated the Transfer Agent upon execution by both parties of a revised Exhibit H bearing a later date than the date indicated thereon. 2. The Transfer Agent shall perform the duties set forth on Exhibit H, or non-affiliated third parties shall cause DST Systems, Inc. and/or its affiliate, Boston Financial Data Services, Inc. ("BFDS"), to perform any or all or part of the services required to be performed by the Administrator under this Transfer Agent pursuant to Exhibit H. Notwithstanding any provision to the contrary in Article 4; providedVII, howeverSection 2 regarding the delegation of duties, the Trust hereby agrees and acknowledges that the Administrator Transfer Agent may delegate its duties with respect to Exhibit H only to DST and/or BFDS. 3. The Transfer Agent hereby consents, and shall remain responsible cause DST and/or BFDS to consent, to the Trust for the acts and omissions of SIMC and such sub-contracted parties. The Administrator will certify annually to the Trust that it has implemented examination and/or inspection by federal regulators, the Trust's AML Programinternal or external auditors, the Trust and the Trust's investment advisers or their designees, to evaluate the Trust's compliance with the USA PATRIOT Act and related rules and regulations and the Transfer Agent agrees to cooperate with such examiners in connection with their review. For purposes of such examination or inspection, the Transfer Agent shall use its best efforts to make available, or cause DST and/or BFDS to make available on similar terms, during normal business hours, all required records and information for review by such examiners. 4. In connection with its duties set forth on Exhibit H and with respect to the Shares for which the Transfer Agent maintains the applicable shareholder information, the Transfer Agent shall maintain all records required to be maintained by the Trust under the USA PATRIOT Act and the rules and regulations promulgated thereunder for the time periods required by such Act or rules or regulations. 5. The Trust acknowledges and agrees that the Administrator (or its agent) will Transfer Agent is agreeing to perform only those aspects of the specific requirements AML Program that have been expressly set forth herein and is not undertaking and shall not be responsible for any other aspect of the Trust's AML Program delegated to or for the Administrator. Notwithstanding this delegation, overall compliance by the Trust shall maintain full responsibility for ensuring that its AML Program is and continues to be reasonably designed to ensure compliance with the USA Patriot PATRIOT Act or the rules and Bank Secrecy Act (collectively, the "AML Acts") and any regulation adopted under the AML Acts (the "Applicable AML Laws"). The Administrator shall maintain policies, procedures and internal controls that are consistent with the Trust's AML Program and the requirement that the Trust employ procedures reasonably designed to achieve compliance with the Applicable AML Laws and the Trust's AML Program. The Trust recognizes that the performance of the AML Services involves the exercise of discretion, which in certain circumstances may result in consequences to the Trust and its Shareholders (such as in the case of the reporting of suspicious activities and the freezing of Shareholders' accounts). The Trust authorizes the Administrator to take such actions in the performance of the AML Services as the Administrator deems appropriate and consistent with the Trust's AML Program and Applicable AML Lawsregulations promulgated thereunder.