BANK SECRECY ACT/ANTI-MONEY LAUNDERING. On a daily basis during Full Launch, provided that Bank and Servicer have established a mutually agreeable scope and procedure, Servicer shall provide a FTP file transmission to Bank containing all transactional activity for each given day within that daily period for each Card, as extracted from Servicer’s data warehouse. Servicer shall reasonably cooperate with Bank in conducting fraud detections, investigations and filing Suspicious Activity Reports with respect to Card transactional activity. If in the course of fraud detection and investigation Servicer identifies suspicious activity that requires filing of a Suspicious Activity Report under Applicable Law, Servicer shall provide Bank with all information within its possession regarding such activity, and cooperate with Bank so that Bank may file a SAR.
BANK SECRECY ACT/ANTI-MONEY LAUNDERING. On a daily basis, provided that Bank and Servicer have established a mutually agreeable scope and procedure, Servicer shall provide a FTP file transmission to Bank containing all transactional activity for each given day within that daily period for each Gift Card, as extracted from Servicer’s data warehouse. Servicer shall reasonably cooperate with Bank in conducting fraud detections, investigations and filing Suspicious Activity Reports with respect to Gift Card transactional activity.
BANK SECRECY ACT/ANTI-MONEY LAUNDERING. (1) Within sixty (60) days, the Board shall review and enhance the Bank’s BSA/AML program and ensure implementation and Bank adherence to a written program of policies and procedures to provide for compliance with the Bank Secrecy Act (“BSA”), as amended (31 U.S.C. §§ 5311 et seq.), the regulations promulgated there under at 31 C.F.R. Part 103, as amended, and 12 C.F.R. Part 21, Subparts B and C, and the rules and regulations of the Office of Foreign Assets Control (“OFAC”) (collectively referred to as the “Bank Secrecy Act” or “BSA”) and for the appropriate identification and monitoring of transactions that pose greater than normal risk for compliance with the BSA. This program shall include the following:
BANK SECRECY ACT/ANTI-MONEY LAUNDERING. (1) Within one hundred and twenty (120) days, the Board shall revise, implement and thereafter ensure Bank adherence to a written program of policies and procedures to ensure compliance with the Bank Secrecy Act, as amended (31 U.S.C. §§ 5311 - 5330), the regulations promulgated thereunder at 31 C.F.R. Part 103, as amended, and 12 C.F.R. Part 21, Subparts B and C (collectively referred to as the Bank Secrecy Act). In revising the Bank's Program, the Board shall refer to the Bank Secrecy Act/Anti-Money Laundering Booklet of the Comptroller's Handbook, September 2000, OCC Advisory Letter 2000-3, April 24, 2000; and any subsequent Bank Secrecy Act/Anti-Money Laundering guidance the OCC may issue. At a minimum, the Bank's written program shall include:
BANK SECRECY ACT/ANTI-MONEY LAUNDERING. Since December 31, 2015, to the knowledge of Presidio, there do not exist any facts or circumstances that would cause Presidio to be deemed to be operating in violation in any material respect of the Bank Secrecy Act, the USA PATRIOT Act, any Order issued as to anti-money laundering by OFAC, or any other applicable anti-money laundering Law or the provisions of the Bank Secrecy Act/anti-money laundering program adopted by Presidio. The Presidio Board has adopted and implemented a Bank Secrecy Act/anti-money laundering program that also satisfies the applicable requirements of the USA PATRIOT Act and the regulations thereunder, and Presidio has not received written notice or other written communication from any Governmental Entity that such program has been deemed ineffective in meeting the requirements of the such Laws. Presidio has complied in all material respects with any requirements to file reports and other necessary documents as required by the USA PATRIOT Act and the regulations thereunder.
BANK SECRECY ACT/ANTI-MONEY LAUNDERING. Since December 31, 2015, to the knowledge of HCC, there do not exist any facts or circumstances that would cause HCC or any of its Subsidiaries to be deemed to be operating in violation in any material respect of the Bank Secrecy Act, the USA PATRIOT Act, any Order issued as to anti-money laundering by OFAC, or any other applicable anti-money laundering Law or the provisions of the Bank Secrecy Act/anti-money laundering program adopted by HCC or any of its Subsidiaries. The HBC Board has adopted and implemented a Bank Secrecy Act/anti-money laundering program that also satisfies the applicable requirements of the USA PATRIOT Act and the regulations thereunder, and none of HCC or any of its Subsidiaries has not received any written notice or other written communication from any Governmental Entity that such program has been deemed ineffective in meeting the requirements of the such Laws. HCC and each of its Subsidiaries has complied in all material respects with any requirements to file reports and other necessary documents as required by the USA PATRIOT Act and the regulations thereunder.
