Common use of Anti-Money Laundering Clause in Contracts

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: (a) as part of processing an application for a Contract, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons; (c) as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the Office of Foreign Asset Control (“OFAC”) list of such persons; (d) as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the OFAC list of such persons; (e) it will ensure that money tendered to the Trust as payment for Trust shares did not originate with a bank lacking a physical place of business (i.e., a “shell” bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s accounts with the Trust; (g) The Trust and the Distributor shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: (a) as part of processing an application for a Contract, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons; (c) as part of processing an application for a Variable Contract, it will verify that no applicant, including prospective principal or beneficial applicant for a Variable Contract Owners, is a “specially designated national” or a person from domiciled or incorporated in an embargoed or “blocked” country as indicated by the Office of Foreign Asset Control (“OFAC”) list of such persons; (db) as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Variable Contract Owner, including a principal or beneficial Contract Owners, owner is a “specially designated national” or a person from domiciled or incorporated in an embargoed or “blocked” country as indicated by the OFAC list of such persons; (ec) it will ensure that money tendered to the Trust as payment for Trust shares did not originate with a bank lacking a physical place of business (i.e., a “shell” bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (fd) if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s accounts with the Trust; (ge) The Trust and the Distributor shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations Applicable Law designed to prevent money “"laundering”", and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “"laundering” " activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: (a) : - as part of processing an application for a Contract, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) , - as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons; (c) , - as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Owners, is a “"specially designated national” " or a person from an embargoed or “"blocked” " country as indicated by the Office of Foreign Asset Control (“"OFAC”") list of such persons; (d) , - as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “"specially designated national” " or a person from an embargoed or “"blocked” " country as indicated by the OFAC list of such persons; (e) , - it will ensure that money tendered to the Trust as payment for Trust shares Shares did not originate with a bank lacking a physical place of business (i.e.I.E., a “"shell” " bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) , and - if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s 's accounts with the Trust; (g) . The Trust and the Distributor shall comply with all applicable laws and regulations Applicable Laws designed to prevent money “"laundering”", and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “"laundering” " activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations designed to prevent money “"laundering”", and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “"laundering” " activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: (a) : - as part of processing an application for a Contract, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) , - as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons; (c) , - as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Owners, is a “"specially designated national” " or a person from an embargoed or “"blocked” " country as indicated by the Office of Foreign Asset Control (“"OFAC”") list of such persons; (d) , - as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “"specially designated national” " or a person from an embargoed or “"blocked” " country as indicated by the OFAC list of such persons; (e) , - it will ensure that money tendered to the Trust as payment for Trust shares did not originate with a bank lacking a physical place of business (i.e., a “"shell” " bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) , and - if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s 's accounts with the Trust; (g) . The Trust and the Distributor shall comply with all applicable laws and regulations designed to prevent money “"laundering”", and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “"laundering” " activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations designed to prevent money “"laundering”", and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “"laundering” " activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: (ai) as part of processing an application for a Contract, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract;, (bii) as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, if required by the Patriot Act reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons;, (ciii) as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Owners, is a “"specially designated national” " or a person from an embargoed or “"blocked” " country as indicated by the Office of Foreign Asset Control (“"OFAC”") list of such persons;, (div) as part of its ongoing compliance with the USA Patriot ActAct and if required by such act, it will, from time to time, reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “"specially designated national” " or a person from an embargoed or “"blocked” " country as indicated by the OFAC Office of Foreign Asset Control ("OFAC") list of such persons;, (ev) it will ensure that money tendered to the Trust as payment for Trust shares did not originate with a bank lacking a physical place of business (i.e., a “"shell” " bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; , and (fvi) if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s 's accounts with the Trust;. (gvii) The Trust and the Distributor shall comply with all applicable laws and regulations designed to prevent money “"laundering”", and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “"laundering” " activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: (a) as part of processing an application for a Contract, if and to the extent applicable, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons; (c) as part of processing an application for a Contract, if and to the extent applicable, it will verify that no applicant, including prospective principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the Office of Foreign Asset Control (“OFAC”) list of such persons; (d) as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the OFAC list of such persons; (e) it will ensure that money tendered to the Trust as payment for Trust shares did not originate with a bank lacking a physical place of business (i.e., a “shell” bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s accounts with the Trust; (g) The Trust and the Distributor shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations designed to prevent money “"laundering”", and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “"laundering” " activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: (a) : o as part of processing an application for a Contract, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) , o as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons; (c) , o as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Owners, is a “"specially designated national” " or a person from an embargoed or “"blocked” " country as indicated by the Office of Foreign Asset Control (“"OFAC”") list of such persons; (d) , o as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “"specially designated national” " or a person from an embargoed or “"blocked” " country as indicated by the OFAC Office of Foreign Asset Control ("OFAC") list of such persons; (e) , o it will ensure that money tendered to the Trust as payment for Trust shares did not originate with a bank lacking a physical place of business (i.e., a “"shell” " bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) , and o if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s 's accounts with the Trust; (g) . The Trust and the Distributor shall comply with all applicable laws and regulations designed to prevent money “"laundering”", and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “"laundering” " activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.121.1. The Company shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: (a) as part of processing an application for a Contract, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons; (c) as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the Office of Foreign Asset Control (“OFAC”) list of such persons; (d) as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the OFAC list of such persons; (e) it will ensure that money tendered to the Trust as payment for Trust shares did not originate with a bank lacking a physical place of business (i.e., a “shell” bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s accounts with the Trust; (g) The Trust and the Distributor shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: (a) : · as part of processing an application for a Contract, it the Company or its designee will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) , · as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, will reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held if required by non-natural persons; (c) applicable law, · as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the Office of Foreign Asset Control (“OFAC”) list of such persons; (d) , · as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the OFAC list of such persons; (e) , · it will ensure that money tendered to the Trust as payment for Trust shares did not originate with a bank lacking a physical place of business (i.e., a “shell” bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) , and · if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s accounts with the Trust; (g) . The Trust and the Distributor shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations designed to prevent money “"laundering”", and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “"laundering” " activities in accordance with Section 314(b) of the USA Patriot Act. In particularHowever, it is recognized that (a) anti-money laundering programs are risk-based and are permitted to take into account the particular entities business and (b) the Contracts will only be offered to certain types of tax qualified retirement plans. . The Company agrees that: (a) : o as part of processing an application for a Contract, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons; (c) o as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Ownersowners, is a “"specially designated national” " or a person from an embargoed or “"blocked” " country as indicated by the Office of Foreign Asset Control (“"OFAC”") list of such persons; (d) , o as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Contract Ownerowner, including a principal or beneficial Contract Ownersowners, is a “"specially designated national” " or a person from an embargoed or “"blocked” " country as indicated by the OFAC list of such persons; (e) it will ensure that money tendered to the Trust as payment for Trust shares did not originate with a bank lacking a physical place of business (i.e., a “shell” bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) and o if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners owners with the Company or of one or more of the Company’s 's accounts with the Trust; (g) . The Trust Trust, Adviser and the Distributor shall comply with all applicable laws and regulations designed to prevent money “"laundering”", and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “"laundering” " activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act. In particularHowever, it is recognized that (a) anti-money laundering programs are risk-based and are permitted to take into account the particular entities business and (b) the Contracts will only be offered to certain types of tax qualified retirement plans. The Company agrees that: (a) : · as part of processing an application for a Contract, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons; (c) · as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Ownersowners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the Office of Foreign Asset Control (“OFAC”) list of such persons; (d) , · as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Contract Ownerowner, including a principal or beneficial Contract Ownersowners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the OFAC list of such persons; (e) it will ensure that money tendered to the Trust as payment for Trust shares did not originate with a bank lacking a physical place of business (i.e., a “shell” bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) and · if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners owners with the Company or of one or more of the Company’s accounts with the Trust; (g) . The Trust Trust, Adviser and the Distributor shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations Applicable Law designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: (a) : · as part of processing an application for a Contract, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) , · as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons; (c) , · as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the Office of Foreign Asset Control (“OFAC”) list of such persons; (d) , · as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the OFAC list of such persons; (e) , · it will ensure that money tendered to the Trust as payment for Trust shares Shares did not originate with a bank lacking a physical place of business (i.e., a “shell” bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) , and · if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s accounts with the Trust; (g) . The Trust and the Distributor shall comply with all applicable laws and regulations Applicable Laws designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: (a) : • it will have agreements with broker dealers that as part of processing an application for a Contract, it the broker dealer will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) , • it will have agreements with broker dealers that as part of its ongoing compliance with the USA Patriot Act, it the broker dealer will, from time to time, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons; (c) , • as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the Office of Foreign Asset Control (“OFAC”) list of such persons; (d) , • as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the OFAC list of such persons; (e) , • it will ensure that money tendered to the Trust as payment for Trust shares did not originate with a bank lacking a physical place of business (i.e., a “shell” bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) , and • if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s accounts with the Trust; (g) . The Trust and the Distributor shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: (a) as part of processing an application for a Contract, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons; (c) as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the Office of Foreign Asset Control (“OFAC”) list of such persons; (d) as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the OFAC list of such persons; (e) it will ensure that money tendered to the Trust as payment for Trust shares did not originate with a bank lacking a physical place of business (i.e., a “shell” bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s accounts with the Trust; (gf) The Trust and the Distributor shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations designed to prevent money “laundering”, ,” and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: (a) : • as part of processing an application for a Contract, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) , • as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons; (c) , • as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the Office of Foreign Asset Control (“OFAC”) list of such persons; (d) , • as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the OFAC Office of Foreign Asset Control (“OFAC”) list of such persons; (e) , • it will ensure that money tendered to the Trust as payment for Trust shares did not originate with a bank lacking a physical place of business (i.e., a “shell” bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) , and • if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s accounts with the Trust; (g) . The Trust and the Distributor shall comply with all applicable laws and regulations designed to prevent money “laundering”, ,” and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations designed to prevent money “"laundering”", and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “"laundering” " activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: (a) : . as part of processing an application for a Contract, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) , . as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons; (c) , . as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Owners, is a “"specially designated national” " or a person from an embargoed or “"blocked” " country as indicated by the Office of Foreign Asset Control (“"OFAC”") list of such persons; (d) , . as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “"specially designated national” " or a person from an embargoed or “"blocked” " country as indicated by the OFAC list of such persons; (e) , . it will ensure that money tendered to the Trust as payment for Trust shares did not originate with a bank lacking a physical place of business (i.e., a “"shell” " bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) , and . if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s 's accounts with the Trust; (g) . The Trust and the Distributor shall comply with all applicable laws and regulations designed to prevent money “"laundering”", and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “"laundering” " activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: (a) as part of processing an application for a Variable Contract, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Variable Contract; (b) as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify the identity of Variable Contract Ownersowners, including the identity of principal and beneficial owners of Variable Contracts held by non-natural persons; (c) as part of processing an application for a Variable Contract, it will verify that no applicant, including prospective principal or beneficial Contract Ownersowners of the Variable Contract, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the Office of Foreign Asset Control (“OFAC”) list of such persons; (d) as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Variable Contract Ownerowner, including a principal or beneficial Contract Ownersowner of the Variable Contract, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the OFAC list of such persons; (e) it will ensure that money tendered to the Trust as payment for Trust shares did not originate with a bank lacking a physical place of business (i.e., a “shell” bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts Fund shares pertaining to such principal or beneficial owners of one or more such Contract Owners with the Company or of one or more of the Company’s accounts with the Trust;Variable Accounts. (g) 8.2. The Trust and the Distributor shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company Society shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company Society agrees that, if applicable to the Society: (a) as part of processing an application for a Contract, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons; (c) as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the Office of Foreign Asset Control (“OFAC”) list of such persons; (d) as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the OFAC list of such persons; (e) it will ensure that money tendered to the Trust as payment for Trust shares did not originate with a bank lacking a physical place of business (i.e., a “shell” bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company Society or of one or more of the CompanySociety’s accounts with the Trust; (g) The Trust and the Distributor shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Company Society information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations designed to prevent money “"laundering”", and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “"laundering” " activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: (a) that it will have written policies and procedures reasonably designed to ensure that : · as part of processing an application for a Contract, it will verify the identity of applicants and, if an applicant is not a natural person, ; will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons; (c) · as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Owners, is a “"specially designated national” " or a person from an embargoed or “"blocked” " country as indicated by the Office of Foreign Asset Control (“"OFAC”") list of such persons; (d) , · as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “"specially designated national” " or a person from an embargoed or “"blocked” " country as indicated by the OFAC Office of Foreign Asset Control ("OFAC") list of such persons; (e) it will ensure that , and · money tendered to the Trust as payment for Trust shares did not originate with a bank lacking a physical place of business (i.e., a “"shell” " bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) if . If any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s 's accounts with the Trust; (g) . The Trust and the Distributor shall comply with all applicable laws and regulations designed to prevent money “"laundering”", and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “"laundering” " activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations designed to prevent money “"laundering”" and financing of terrorist activity, and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “"laundering” " activities in accordance with Section 314(b) of the USA Patriot Act. In addition, the Company shall adopt and implement policies and procedures reasonably designed to achieve compliance with the applicable laws and regulations designed to prevent money "laundering" and financing of terrorist activity. [In particular, the Company agrees that: (a) : - as part of processing an application for a Contract, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) , - as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons; (c) , - as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Owners, is a “"specially designated national” " or a person from an embargoed or “"blocked” " country as indicated by the Office of Foreign Asset Control (“"OFAC”") list of such persons; (d) , - as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “"specially designated national” " or a person from an embargoed or “"blocked” " country as indicated by the OFAC list of such persons; (e) , - it will ensure that money tendered to the Trust as payment for Trust shares did not originate with a bank lacking a physical place of business (i.e., a “"shell” " bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) , and - if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s 's accounts with the Trust; (g) .] The Trust and the Distributor shall comply with all applicable laws and regulations designed to prevent money “"laundering”", and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “"laundering” " activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations designed to prevent money “"laundering”", and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “"laundering” " activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: (a) : • as part of processing an application for a Contract, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) , • as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-non­ natural persons; (c) , • as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Owners, is a “"specially designated national” " or a person from an embargoed or “"blocked” " country as indicated by the Office of Foreign Asset Control (“"OFAC”") list of such persons; (d) , • as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “"specially designated national” " or a person from an embargoed or “"blocked” " country as indicated by the OFAC Office of Foreign Asset Control ("OFAC") list of such persons; (e) , • it will ensure that money tendered to the Trust as payment for Trust shares did not originate with a bank lacking a physical place of business (i.e., a “"shell” " bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) , and if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s 's accounts with the Trust; (g) . The Trust and the Distributor shall comply with all applicable laws and regulations designed to prevent money “"laundering”", and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “"laundering” " activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations Applicable Law designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: (a) : • as part of processing an application for a Contract, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) , • as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons; (c) , • as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the Office of Foreign Asset Control (“OFAC”) list of such persons; (d) , • as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the OFAC list of such persons; (e) , • it will ensure that money tendered to the Trust as payment for Trust shares Shares did not originate with a bank lacking a physical place of business (i.e., a “shell” bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) , and • if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s accounts with the Trust; (g) . The Trust and the Distributor shall comply with all applicable laws and regulations Applicable Laws designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. 21.1 The Company shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: (a) a. as part of processing an application for a Contract, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) b. as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons; (c) c. as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the Office of Foreign Asset Control (“OFAC”) list of such persons; (d) d. as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the OFAC list of such persons; (e) e. it will ensure that money tendered to the Trust as payment for Trust shares did not originate with a bank lacking a physical place of business (i.e., a “shell” bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) f. if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s accounts with the Trust; (g) g. The Trust and the Distributor shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations Applicable Law designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: (a) , to the extent required by Applicable Law: • as part of processing an application for a Contract, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) , • as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons; (c) , • as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the Office of Foreign Asset Control (“OFAC”) list of such persons; (d) , • as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the OFAC list of such persons; (e) , • it will ensure that money tendered to the Trust as payment for Trust shares Shares did not originate with a bank lacking a physical place of business (i.e., a “shell” bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) , and • if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s accounts with the Trust; (g) . The Trust and the Distributor shall comply with all applicable laws and regulations Applicable Laws designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: (a) as part of processing an application for a Contract, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify will verify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons; (c) as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the Office of Foreign Asset Control (“OFAC”) list of such persons; (d) as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify will verify that no Contract Owner, including a principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the OFAC list of such persons; (e) it will ensure that money tendered to the Trust as payment for Trust shares did not originate with a bank lacking a physical place of business (i.e., a “shell” bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s accounts with the Trust; (g) The Trust and the Distributor shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: (a) as part of processing an application for a Contract, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons; (c) as part of processing an application for a Contract, it will verify verity that no applicant, including prospective principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the Office of Foreign Asset Control (“OFAC”) list of such persons; (d) as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the OFAC list of such persons; (e) it will ensure that money tendered to the Trust as payment for Trust shares did not originate with a bank lacking a physical place of business (i.e., a “shell” bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s accounts with the Trust; (g) The Trust and the Distributor shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations designed to prevent money “"laundering”", and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “"laundering” " activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: (a) : o as part of processing an application for a Contract, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons; (c) o as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Owners, is a “"specially designated national” " or a person from an embargoed or “"blocked” " country as indicated by the Office of Foreign Asset Control (“"OFAC”") list of such persons; (d) , o as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “"specially designated national” " or a person from an embargoed or “"blocked” " country as indicated by the OFAC Office of Foreign Asset Control ("OFAC") list of such persons; (e) it will ensure that money tendered to the Trust as payment for Trust shares did not originate with a bank lacking a physical place of business (i.e., a “shell” bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) and o if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s 's accounts with the Trust; (g) . The Trust and the Distributor shall comply with all applicable laws and regulations designed to prevent money “"laundering”", and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “"laundering” " activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations Applicable Law designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: (a) as : • As part of processing an application for a Contract, it will verify the identity of applicants andit, if an applicant is not a natural personor its designee, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) as applicants, • As part of its ongoing compliance with the USA Patriot Act, it it, or its designee, will, from time to time, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons; (c) • as part of processing an application for issuing a Contract, and on a regular basis thereafter, it will verify that no applicant, including prospective principal or beneficial Contract Owners, Owner is a “specially designated national” or a blocked person from an embargoed or “blocked” country as indicated by the Office of Foreign Asset Control (“OFAC”) list of such persons; (d) as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “specially designated national” person domiciled or incorporated in a person from an embargoed or “blocked” country as indicated by the OFAC list of such persons; (e) subject to comprehensive U.S. sanctions, • it will ensure that money tendered to the Trust as payment for Trust shares Shares did not originate with a bank lacking a physical place of business (i.e., a “shell” bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) , and • if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s accounts with the Trust; (g) . The Trust and the Distributor shall comply with all applicable laws and regulations Applicable Laws designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations designed to prevent money “"laundering”", and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “"laundering” " activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: (a) : o as part of processing an application for a Contract, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) , o as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons; (c) , o as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Owners, is a “"specially designated national” " or a person from an embargoed or “"blocked” " country as indicated by the Office of Foreign Asset Control (“"OFAC”") list of such persons; (d) , o as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “"specially designated national” " or a person from an embargoed or “"blocked” " country as indicated by the OFAC Office of Foreign Asset Control ("OFAC") list of such persons; (e) , o it will ensure that money tendered to the Trust as payment for Trust shares did not originate with a bank lacking a physical place of business (i.e.I.E., a “"shell” " bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) , and o if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s 's accounts with the Trust; (g) . The Trust and the Distributor shall comply with all applicable laws and regulations designed to prevent money “"laundering”", and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “"laundering” " activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: (ai) as part of processing an application for a Contract, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract;, (bii) as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons;, (ciii) as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the Office of Foreign Asset Control (“OFAC”) list of such persons;, (div) as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the OFAC Office of Foreign Asset Control (“OFAC”) list of such persons;, (ev) it will ensure that money tendered to the Trust as payment for Trust shares did not originate with a bank lacking a physical place of business (i.e., a “shell” bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; , and (fvi) if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s accounts with the Trust;, (gvii) The Trust and the Distributor shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations Applicable Law designed to prevent money “"laundering”", and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “"laundering” " activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: (a) : . as part of processing an application for a Contract, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) , . as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify the identity of Contract Owners, including the # 1286928 v.9 identity of principal and beneficial owners of Contracts held by non-natural persons; (c) , . as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Owners, is a “"specially designated national” " or a person from an embargoed or “"blocked” " country as indicated by the Office of Foreign Asset Control (“"OFAC”") list of such persons; (d) , . as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “"specially designated national” " or a person from an embargoed or “"blocked” " country as indicated by the OFAC list of such persons; (e) , . it will ensure that money tendered to the Trust as payment for Trust shares Shares did not originate with a bank lacking a physical place of business (i.e.I.E., a “"shell” " bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) , and . if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s 's accounts with the Trust; (g) . The Trust and the Distributor shall comply with all applicable laws and regulations Applicable Laws designed to prevent money “"laundering”", and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “"laundering” " activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations designed to prevent money “"laundering”", and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “"laundering” " activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: (a) that to the extent required by applicable laws or regulations: - as part of processing an application for a Contract, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) , - as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons; (c) , - as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Owners, is a “"specially designated national” " or a person from an embargoed or “"blocked” " country as indicated by the Office of Foreign Asset Control (“"OFAC”") list of such persons; (d) , - as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “"specially designated national” " or a person from an embargoed or “"blocked” " country as indicated by the OFAC list of such persons; (e) , - it will ensure that money tendered to the Trust as payment for Trust shares did not originate with a bank lacking a physical place of business (i.e.I.E., a “"shell” " bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) , and - if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s 's accounts with the Trust; (g) . The Trust and the Distributor shall comply with all applicable laws and regulations designed to prevent money “"laundering”", and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “"laundering” " activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: (a) : ● as part of processing an application for a Contract, it the Company or its designee will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) , ● as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, will reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held if required by non-natural persons; (c) applicable law, ● as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the Office of Foreign Asset Control (“OFAC”) list of such persons; (d) , ● as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the OFAC list of such persons; (e) , ● it will ensure that money tendered to the Trust as payment for Trust shares did not originate with a bank lacking a physical place of business (i.e., a “shell” bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) , and ● if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s accounts with the Trust; (g) . The Trust and the Distributor shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations Applicable Laws designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: (a) : • as part of processing an application for a Contract, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) , • as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons; (c) , • as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the Office of Foreign Asset Control (“OFAC”) list of such persons; (d) , • as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the OFAC list of such persons; (e) , • it will ensure that money tendered to the Trust as payment for Trust shares Shares did not originate with a bank lacking a physical place of business (i.e., a “shell” bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) , and • if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s accounts with the Trust; (g) . The Trust and the Distributor shall comply with all applicable laws and regulations Applicable Laws designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act. 2. The Participation Agreement is hereby amended to add the following as a new Section 5.12 of the Agreement:

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations Applicable Law designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: (a) : • as part of processing an application for a Contract, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) , • as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons; (c) , • as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the Office of Foreign Asset Control (“OFAC”) list of such persons; (d) , • as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the OFAC list of such persons; (e) , • it will ensure that money tendered to the Trust as payment for Trust shares Shares did not originate with a bank lacking a physical place of business business (i.e.i. e., a “shell” bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) , and • if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s accounts with the Trust; (g) . The Trust and the Distributor shall comply with all applicable laws and regulations Applicable Laws designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations designed to prevent money “"laundering”", and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “"laundering” " activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: (a) : • as part of processing an application for a Contract, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) , as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons; (c) , • as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Owners, is a “"specially designated national” " or a person from an embargoed or “"blocked” " country as indicated by the Office of Foreign Asset Control (“"OFAC”") list of such persons; (d) , • as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “"specially designated national” " or a person from an embargoed or “"blocked” " country as indicated by the OFAC list of such persons; (e) , • it will ensure that money tendered to the Trust as payment for Trust shares did not originate with a bank lacking a physical place of business (i.e., a “"shell” " bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) , and • if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s 's accounts with the Trust; (g) . The Trust and the Distributor shall comply with all applicable laws and regulations designed to prevent money “"laundering”", and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “"laundering” " activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: (a) : • as part of processing an application for a Contract, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) , • as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons; (c) , • as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the Office of Foreign Asset Control (“OFAC”) list of such persons; (d) , • as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the OFAC Office of Foreign Asset Control (“OFAC”) list of such persons; (e) , • it will ensure that money tendered to the Trust as payment for Trust shares did not originate with a bank lacking a physical place of business (i.e., a “shell” bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) , and • if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s accounts with the Trust; (g) . The Trust and the Distributor shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot PATRIOT Act. In particular, the Company agrees that: (a) as part of processing an application for a Variable Contract, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Variable Contract; (b) as part of its ongoing compliance with the USA Patriot PATRIOT Act, it will, from time to time, reverify the identity of Variable Contract Ownersowners, including the identity of principal and beneficial owners of Variable Contracts held by non-natural persons; (c) as part of processing an application for a Variable Contract, it will verify that no applicant, including prospective principal or beneficial Variable Contract Ownersowners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the Office of Foreign Asset Control (“OFAC”) list of such persons; (d) as part of its ongoing compliance with the USA Patriot PATRIOT Act, it will, from time to time, reverify that no Variable Contract Ownerowner, including a principal or beneficial Variable Contract Ownersowners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the OFAC list of such persons; (e) it will ensure that money tendered to the Trust as payment for Trust Fund shares did not originate with a bank lacking a physical place of business (i.e., a “shell” bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot PATRIOT Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Variable Contract Owners owners with the Company or of one or more of the Company’s accounts Separate Accounts with the Trust; (g) The Trust and the Distributor shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot PATRIOT Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: (a) as part of processing an application for a Contract, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons; (c) as part of processing an application for a Variable Contract, it will verify that no applicant, including prospective principal or beneficial applicant for a Variable Contract Owners, is a “specially designated national” or a person from domiciled or incorporated in an embargoed or “blocked” country as indicated by the Office of Foreign Asset Control (“OFAC”) list of such persons; (db) as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Variable Contract Owner, including a principal or beneficial Contract Owners, owner is a “specially designated national” or a person from domiciled or incorporated in an embargoed or “blocked” country as indicated by the OFAC list of such persons; (ec) it will ensure that money tendered to the Trust as payment for Trust shares did not originate with a bank lacking a physical place of business (i.e., a “shell” bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (fd) if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s accounts with the Trust; ; (ge) The Trust and the Distributor shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations designed to prevent money “"laundering”", and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “"laundering” " activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: (a) : - as part of processing an application for a Contract, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) , - as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons; (c) , - as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Owners, is a “"specially designated national” " or a person from an embargoed or “"blocked” " country as indicated by the Office of Foreign Asset Control (“"OFAC”") list of such persons; (d) , - as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “"specially designated national” " or a person from an embargoed or “"blocked” " country as indicated by the OFAC list of such persons; (e) , - it will ensure that money tendered to the Trust as payment for Trust shares did not originate with a bank lacking a physical place of business (i.e.I.E., a “"shell” " bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) , and - if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s 's accounts with the Trust; (g) . The Trust and the Distributor shall comply with all applicable laws and regulations designed to prevent money “"laundering”", and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “"laundering” " activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations designed to prevent money “"laundering”", and if required or permitted by such applicable laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “"laundering” " activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees thatthat it will use best efforts to: (a) as part of processing an application for a Contract, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract;, (b) as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons;, (c) as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Owners, is a “"specially designated national” " or a person from an embargoed or “"blocked” " country as indicated by the Office of Foreign Asset Control (“"OFAC”") list of such persons;, (d) as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, time reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “"specially designated national” " or a person from an embargoed or “"blocked” " country as indicated by the OFAC list of such persons;, (e) it will ensure that money tendered to the Trust as payment for Trust shares did not originate with a bank lacking a physical place of business (i.e.I.E., a “"shell” " bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; , and (f) if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s 's accounts with the Trust; (g) . The Trust and the Distributor shall comply with all applicable laws and regulations designed to prevent money “"laundering”", and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “"laundering” " activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply in all material respects with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: (a) : • as part of processing an application for a Contract, Contract it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) , • as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons; (c) , • as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the Office of Foreign Asset Control (“OFAC”) list of such persons; (d) , • as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the OFAC Office of Foreign Asset Control (“OFAC”) list of such persons; (e) , • it will ensure that money tendered to the Trust as payment for Trust shares did not originate with a bank lacking a physical place of business (i.e., a “shell” bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) , and • if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s accounts with the Trust; (g) Trust The Trust and the Distributor shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: (a) as part of processing an application for a Contract, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, if and to an extent required by law, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons; (c) as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the Office of Foreign Asset Control (“OFAC”) list of such persons; (d) as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the OFAC list of such persons; (e) it will ensure that money tendered to the Trust as payment for Trust shares did not originate with a bank lacking a physical place of business (i.e., a “shell” bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s accounts with the Trust; (g) The Trust and the Distributor shall comply with all applicable laws and regulations designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations Applicable Law designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act. In particular, if required by applicable law, the Company agrees that: (a) : · as part of processing an application for a Contract, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) , · as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons; (c) , · as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the Office of Foreign Asset Control (“OFAC”) list of such persons; (d) , · as part of its ongoing compliance with the USA Patriot Act, it will, from time to time, reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “specially designated national” or a person from an embargoed or “blocked” country as indicated by the OFAC list of such persons; (e) , · it will ensure that money tendered to the Trust as payment for Trust shares Shares did not originate with a bank lacking a physical place of business (i.e., a “shell” bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) , and · if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s accounts with the Trust; (g) . The Trust and the Distributor shall comply with all applicable laws and regulations Applicable Laws designed to prevent money “laundering”, and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “laundering” activities in accordance with Section 314(b) of the USA Patriot Act.

Anti-Money Laundering. 8.1. The Company shall comply with all applicable laws and regulations designed to prevent money “"laundering”", and if required by such laws or regulations, to share with the Trust information about individuals, entities, organizations and countries suspected of possible terrorist or money “"laundering” " activities in accordance with Section 314(b) of the USA Patriot Act. In particular, the Company agrees that: (a) : - as part of processing an application for a Contract, it will verify the identity of applicants and, if an applicant is not a natural person, will verify the identity of prospective principal and beneficial owners submitting an application for a Contract; (b) , - as part of its ongoing compliance with the USA Patriot Act, if required by law, it will, from time to time, reverify the identity of Contract Owners, including the identity of principal and beneficial owners of Contracts held by non-natural persons; (c) , - as part of processing an application for a Contract, it will verify that no applicant, including prospective principal or beneficial Contract Owners, is a “"specially designated national” " or a person from an embargoed or “"blocked” " country as indicated by the Office of Foreign Asset Control (“"OFAC”") list of such persons; (d) , - as part of its ongoing compliance with the USA Patriot Act, if required by law, it will, from time to time, reverify that no Contract Owner, including a principal or beneficial Contract Owners, is a “"specially designated national” " or a person from an embargoed or “"blocked” " country as indicated by the OFAC Office of Foreign Asset Control ("OFAC") list of such persons; (e) , - it will ensure that money tendered to the Trust as payment for Trust shares did not originate with a bank lacking a physical place of business (i.e., a “"shell” " bank) or from a country or territory named on the list of high-risk or non-cooperating countries or jurisdictions published by the Financial Action Task Force; and (f) , and - if any of the foregoing cease to be true, the Trust or its agents, in compliance with the USA Patriot Act or Bank Secrecy Act, may seek authority to block transactions in Account units arising from accounts of one or more such Contract Owners with the Company or of one or more of the Company’s 's accounts with the Trust; (g) . The Trust and the Distributor shall comply with all applicable laws and regulations designed to prevent money “"laundering”", and if required by such laws or regulations, to share with the Company information about individuals, entities, organizations and countries suspected of possible terrorist or money “"laundering” " activities in accordance with Section 314(b) of the USA Patriot Act.