Common use of Dealer’s Compliance with Anti-Money Laundering Rules and Regulations Clause in Contracts

Dealer’s Compliance with Anti-Money Laundering Rules and Regulations. The Dealer acknowledges that investors who purchase Shares through Dealer are “customers” of Dealer and not the Dealer Manager. The Dealer hereby represents that it is subject to the anti-money laundering provisions of FINRA and Section 326 of the USA PATRIOT Act of 2001 and the implementing rules and regulations promulgated thereunder in connection with broker/dealers’ anti-money laundering obligations (the “AML Rules”). The Dealer hereby represents that it has adopted and implemented, and will maintain an anti-money laundering compliance program (“AML Program”) in compliance with the AML Rules including, without limitation, a customer identification program and the identification and reporting of suspicious activity. The Dealer shall, upon request by the Dealer Manager, provide a certification to the Dealer Manager that, as of the date of such certification (i) its AML Program is consistent with the applicable AML Rules and (ii) it is currently in compliance with all AML Rules, specifically including, but not limited to, the customer identification program requirements.