Common use of Description of AML Procedures1 Clause in Contracts

Description of AML Procedures1. 4.1 Consistent with the services provided by BOSTON FINANCIAL and with respect to the ownership of Shares in the Trust for which BOSTON FINANCIAL maintains the applicable Shareholder information, BOSTON FINANCIAL shall: (a) On a daily basis, submit all new customer account registrations and registration changes against the Office of Foreign Assets Control (“OFAC”) database, the Politically Exposed Persons (“PEP”) database, and such other lists or databases as may be required from time to time by applicable regulatory authorities; (b) Submit all account registrations through OFAC database, the PEP database, and such other lists or databases as may be required from time to time by applicable regulatory authorities; (c) On a daily basis, submit special payee information from checks, outgoing wires and systematic withdrawal files through the OFAC database; (d) Review certain types of redemption transactions that occur within thirty (30) days of an account establishment, registration change, or banking information change (e.g. multiple purchases followed by a large redemption; large purchases into small balance accounts; large check redemptions; special payee redemptions by wire; redemption by wire within 30 days of banking information change; rapid depletion of account balance after establishment; and redemption by check within 30 days of address change); (e) Review wires sent pursuant to banking instructions other than those on file with BOSTON FINANCIAL; (f) Review accounts with small balances followed by large purchases; 1 The accounts, transactions, items and activity reviewed in each case are subject to additional detail (including certain standard exclusions) as set forth in the AML Procedures of BOSTON FINANCIAL, which have been made available to the Trust and which may be modified by BOSTON FINANCIAL from time to time. (g) Review accounts with frequent activity within a specified date range followed by a large redemption; (h) Review purchase and redemption activity by check that meets or exceeds $100,000 threshold on any given day; (i) Determine when a suspicious activity report (“SAR”) should be filed as required by regulations applicable to mutual funds; prepare and file the SAR; provide the Trust with a copy of the SAR within a reasonable time after filing; and notify the Trust if any further communication is received from the U.S. Department of the Treasury or other law enforcement agencies regarding such filing; (j) Compare account information to any FinCEN request received by the Trust and provided to BOSTON FINANCIAL pursuant to 31 C.F.R. 1010.52. Provide the Trust with the necessary information for it to respond to such request within required time frame; (i) Take reasonable steps to verify the identity of any person seeking to become a new customer of the Trust and notify the Trust in the event such person cannot be verified, (ii) Maintain records of the information used to verify the person’s identity, as required, and (iii) Determine whether the person appears on any lists of known or suspected terrorists or terrorist organizations provided to the Trust by any government agency; (l) Conduct due diligence and if required, enhanced due diligence in accordance with 31 C.F.R. 1010.610 for new and existing correspondent accounts for foreign financial institutions (as defined in 31 C.F.R. 1010.605). BOSTON FINANCIAL will perform an assessment of the money laundering risk presented by the account based on a consideration of relevant factors in accordance with applicable law and information provided by the foreign financial institution in a financial institution questionnaire. If an account is determined to have a medium or above risk-ranking, BOSTON FINANCIAL will monitor the account on a monthly basis for unusual activity. In the situation where due diligence cannot be completed with respect to an account, BOSTON FINANCIAL will contact the Trust’s AML Officer for further instruction. (m) On an ongoing basis, conduct due diligence to determine if the Trust is involved with any foreign jurisdiction, institution, class of transactions and a type of account designated, from time to time, by the U.S. Department of Justice in order to identify and take certain “special measures” against such entities as required under 31 U.S.C. 5318A. (n) BOSTON FINANCIAL shall create and retain records required under 31 C.F.R. 1010.410 in connection with the transmittals of funds in amounts equal to or in excess of $3,000, and transmit such information on the transactions to the receiving financial institutions. (o) It is not anticipated that BOSTON FINANCIAL will accept currency; however, should it occur, BOSTON FINANCIAL will advise the Trust of any transactions in currency required to be reported by the Trust under 31 C.F.R. 1010.310 and 1010.340. 4.2 In the event that BOSTON FINANCIAL detects activity as a result of the foregoing procedures, which necessitates the filing by BOSTON FINANCIAL of a SAR or other similar report or notice to OFAC, then BOSTON FINANCIAL shall also immediately notify the Trust, unless prohibited by applicable law. 4.3 BOSTON FINANCIAL will maintain a program of policies and procedures that are reasonably designed to assist the Trust in the detection of patterns, practices, or specific activity that indicates the possible existence of identity theft (“Red Flags”) that may arise in the performance of BOSTON FINANCIAL’s obligations under this Agreement. BOSTON FINANCIAL shall report any detected Red Flags to the Trust.

Description of AML Procedures1. 4.1 Consistent with the services provided by BOSTON FINANCIAL and with respect to the ownership of Shares in the Trust for which BOSTON FINANCIAL maintains the applicable Shareholder information, BOSTON FINANCIAL shall: (a) On a daily basis, submit all new customer account registrations and registration changes against the Office of Foreign Assets Control (“OFAC”) database, the Politically Exposed Persons (“PEP”) database, and such other lists or databases as may be required from time to time by applicable regulatory authorities; (b) Submit all account registrations through OFAC database, the PEP database, and such other lists or databases as may be required from time to time by applicable regulatory authorities; (c) On a daily basis, submit special payee information from checks, outgoing wires and systematic withdrawal files through the OFAC database; (d) Review certain types of redemption transactions that occur within thirty (30) days of an account establishment, registration change, or banking information change (e.g. multiple purchases followed by a large redemption; large purchases into small balance accounts; large check redemptions; special payee redemptions by wire; redemption by wire within 30 days of banking information change; rapid depletion of account balance after establishment; and redemption by check within 30 days of address change); (e) Review wires sent pursuant to banking instructions other than those on file with BOSTON FINANCIAL; (f) Review accounts with small balances followed by large purchases; 1 The accounts, transactions, items and activity reviewed in each case are subject to additional detail (including certain standard exclusions) as set forth in the AML Procedures of BOSTON FINANCIAL, which have been made available to the Trust and which may be modified by BOSTON FINANCIAL from time to time. . (g) Review accounts with frequent activity within a specified date range followed by a large redemption; (h) Review purchase and redemption activity by check that meets or exceeds $100,000 threshold on any given day; (i) Determine when a suspicious activity report (“SAR”) should be filed as required by regulations applicable to mutual funds; prepare and file the SAR; provide the Trust with a copy of the SAR within a reasonable time after filing; and notify the Trust if any further communication is received from the U.S. Department of the Treasury or other law enforcement agencies regarding such filing; (j) Compare account information to any FinCEN request received by the Trust and provided to BOSTON FINANCIAL pursuant to 31 C.F.R. 1010.521010.520. Provide the Trust with the necessary information for it to respond to such request within required time frame; (i) Take reasonable steps to verify the identity of any person seeking to become a new customer of the Trust and notify the Trust in the event such person cannot be verified, (ii) Maintain records of the information used to verify the person’s identity, as required, and (iii) Determine whether the person appears on any lists of known or suspected terrorists or terrorist organizations provided to the Trust by any government agency; (l) Conduct due diligence and if required, enhanced due diligence in accordance with 31 C.F.R. 1010.610 for new and existing correspondent accounts for foreign financial institutions (as defined in 31 C.F.R. 1010.605). BOSTON FINANCIAL will perform an assessment of the money laundering risk presented by the account based on a consideration of relevant factors in accordance with applicable law and information provided by the foreign financial institution in a financial institution questionnaire. If an account is determined to have a medium or above risk-ranking, BOSTON FINANCIAL will monitor the account on a monthly basis for unusual activity. In the situation where due diligence cannot be completed with respect to an account, BOSTON FINANCIAL will contact the Trust’s AML Officer for further instruction. (m) On an ongoing basisUpon the request by the Trust, conduct due diligence to determine if the Trust is involved with any foreign jurisdiction, institution, class of transactions and a type of account designated, from time to time, by the U.S. Department of Justice in order to identify and take certain “special measures” against such entities as required under 31 U.S.C. 5318A. (n) BOSTON FINANCIAL shall create and retain records required under 31 C.F.R. 1010.410 in connection with the transmittals of funds in amounts equal to or in excess of $3,000, and transmit such information on the transactions to the receiving financial institutions. (o) It is not anticipated that BOSTON FINANCIAL will accept currency; however, should it occur, BOSTON FINANCIAL will advise the Trust of any transactions in currency required to be reported by the Trust under 31 C.F.R. 1010.310 and 1010.340. 4.2 In the event that BOSTON FINANCIAL detects activity as a result of the foregoing procedures, which necessitates the filing by BOSTON FINANCIAL of a SAR or other similar report or notice to OFAC, then BOSTON FINANCIAL shall also immediately notify the Trust, unless prohibited by applicable law. 4.3 BOSTON FINANCIAL will maintain a program of policies and procedures that are reasonably designed to assist the Trust in the detection of patterns, practices, or specific activity that indicates the possible existence of identity theft (“Red Flags”) that may arise in the performance of BOSTON FINANCIAL’s obligations under this Agreement. BOSTON FINANCIAL shall report any detected Red Flags to the Trust.

Description of AML Procedures1. 4.1 Consistent with the services provided by BOSTON FINANCIAL and with respect to the ownership of Shares in the Trust for which BOSTON FINANCIAL maintains the applicable Shareholder information, BOSTON FINANCIAL shall: (a) On a daily basis, submit all new customer account registrations and registration changes against the Office of Foreign Assets Control (“OFAC”) database, the Politically Exposed Persons (“PEP”) database, and such other lists or databases as may be required from time to time by applicable regulatory authorities; (b) Submit all account registrations through OFAC database, the PEP database, and such other lists or databases as may be required from time to time by applicable regulatory authorities; (c) On a daily basis, submit special payee information from checks, outgoing wires and systematic withdrawal files through the OFAC database; (d) Review certain types of redemption transactions that occur within thirty (30) days of an account establishment, registration change, or banking information change (e.g. multiple purchases followed by a large redemption; large purchases into small balance accounts; large check redemptions; special payee redemptions by wire; redemption by wire within 30 days of banking information change; rapid depletion of account balance after establishment; and redemption by check within 30 days of address change); (e) Review wires sent pursuant to banking instructions other than those on file with BOSTON FINANCIAL; (f) Review accounts with small balances followed by large purchases; 1 The accounts, transactions, items and activity reviewed in each case are subject to additional detail (including certain standard exclusions) as set forth in the AML Procedures of BOSTON FINANCIAL, which have been made available to the Trust and which may be modified by BOSTON FINANCIAL from time to time. . (g) Review accounts with frequent activity within a specified date range followed by a large redemption; (h) Review purchase and redemption activity by check per tax identification number (TIN) within the Trust to determine if the activity for that meets or exceeds TIN exceeded the $100,000 threshold on any given day; (i) Determine when a suspicious activity report (“SAR”) should be filed as required by regulations applicable to mutual funds; prepare and file the SAR; provide the Trust with a copy of the SAR within a reasonable time after filing; and notify the Trust if any further communication is received from the U.S. Department of the Treasury or other law enforcement agencies regarding such filing; (j) Compare account information to any FinCEN request received by the Trust and provided to BOSTON FINANCIAL pursuant to 31 C.F.R. 1010.521010.520. Provide the Trust with the necessary information for it to respond to such request within required time frame; (i) Take reasonable steps to verify the identity of any person seeking to become a new customer of the Trust and notify the Trust in the event such person cannot be verified, (ii) Maintain records of the information used to verify the person’s identity, as required, and (iii) Determine whether the person appears on any lists of known or suspected terrorists or terrorist organizations provided to the Trust by any government agency; (l) Conduct due diligence and if required, enhanced due diligence in accordance with 31 C.F.R. 1010.610 for new and existing correspondent accounts for foreign financial institutions (as defined in 31 C.F.R. 1010.605). BOSTON FINANCIAL will perform an assessment of the money laundering risk presented by the account based on a consideration of relevant factors in accordance with applicable law and information provided by the foreign financial institution in a financial institution questionnaire. If an account is determined to have a medium or above risk-ranking, BOSTON FINANCIAL will monitor the account on a monthly basis for unusual activity. In the situation where due diligence cannot be completed with respect to an account, BOSTON FINANCIAL will contact the Trust’s AML Officer for further instruction. (m) On an ongoing basisUpon the request by the Trust, conduct due diligence to determine if the Trust is involved with any foreign jurisdiction, institution, class of transactions and a type of account designated, from time to time, by the U.S. Department of Justice in order to identify and take certain “special measures” against such entities as required under 31 U.S.C. 5318A. (n) BOSTON FINANCIAL shall create and retain records required under 31 C.F.R. 1010.410 in connection with the transmittals of funds in amounts equal to or in excess of $3,000, and transmit such information on the transactions to the receiving financial institutions. (o) It is not anticipated that BOSTON FINANCIAL will accept currency; however, should it occur, BOSTON FINANCIAL will advise the Trust of any transactions in currency required to be reported by the Trust under 31 C.F.R. 1010.310 and 1010.340. 4.2 In the event that BOSTON FINANCIAL detects activity as a result of the foregoing procedures, which necessitates the filing by BOSTON FINANCIAL of a SAR or other similar report or notice to OFAC, then BOSTON FINANCIAL shall also immediately notify the Trust, unless prohibited by applicable law. 4.3 BOSTON FINANCIAL will maintain a program of policies and procedures that are reasonably designed to assist the Trust in the detection of patterns, practices, or specific activity that indicates the possible existence of identity theft (“Red Flags”) that may arise in the performance of BOSTON FINANCIAL’s obligations under this Agreement. BOSTON FINANCIAL shall report any detected Red Flags to the Trust.