Common use of Economic Sanctions, Anti-Money Laundering and Anti-Corruption Clause in Contracts

Economic Sanctions, Anti-Money Laundering and Anti-Corruption. None of Borrower, any Guarantor, any Key Principal, or any Principal, nor to Borrower’s knowledge, its general partners, managing members, managers (if non-member managed), or any Person owning or controlling any of them: (1) is in violation of: (A) any applicable anti-money laundering laws, including those contained in the Bank Secrecy Act; (B) any applicable economic sanction laws administered by OFAC or by the United States Department of State; or (C) any applicable anti-drug trafficking, anti-terrorism, or anti-corruption laws, civil or criminal; or (2) is a Person: (A) that is charged with, or has reason to believe that he, she or it is under investigation for, any violation of any such laws; (B) that has been convicted of any violation of, has been subject to civil penalties pursuant to, or had any of its property seized or forfeited under any such laws; (C) named on the list of “Specially Designated Nationals or Blocked Persons” maintained by OFAC (or any successor United States government office or list), or any similar list maintained by the United States Department of State (or any successor United States government office or list); (D) with whom any United States Person, any entity organized under the laws of the United States or its constituent states or territories, or any entity, regardless of where organized, having its principal place of business within the United States or any of its territories, is prohibited from transacting business of the type contemplated by this Loan Agreement and the other Loan Documents under any other applicable law; or (E) that is owned, controlled by, or affiliated with any Person identified in clause (A), (B), (C), and/or (D) of this Section 4.01(g)(2); or (3) is in violation of any obligation to maintain appropriate internal controls as required by the governing laws of the jurisdiction of such Person as are necessary to ensure compliance with the economic sanctions, anti-money laundering and anti-corruption laws of the United States and the jurisdiction where the Person resides, is domiciled or has its principal place of business.

Economic Sanctions, Anti-Money Laundering and Anti-Corruption. None of Borrower, any Guarantor, any Key Principal, or any Principal, nor to Borrower’s knowledge, its general partners, managing members, managers (if non-member managed), or any Person owning or controlling any of them: (1) is in violation of: (A) any applicable anti-money laundering laws, including those contained in the Bank Secrecy Act; (B) any applicable economic sanction laws administered by OFAC or by the United States Department of State; or (C) any applicable anti-drug trafficking, anti-terrorism, or anti-corruption laws, civil or criminal; or (2) is a Person: (A) that is charged with, or has reason to believe that he, she or it is under investigation for, any violation of any such laws; (B) that has been convicted of any violation of, has been subject to civil penalties pursuant to, or had any of its property seized or forfeited under any such laws; (C) named on the list of “Specially Designated Nationals or Blocked Persons” maintained by OFAC (or any successor United States government office or list), or any similar list maintained by the United States Department of State (or any successor United States government office or list); (D) with whom any United States Person, any entity organized under the laws of the United States or its constituent states or territories, or any entity, regardless of where organized, having its principal place of business within the United States or any of its territories, is prohibited from transacting business of the type contemplated by this Loan Agreement and the other Loan Documents under any other applicable law; or (E) that is owned, controlled by, or affiliated with any Person identified in clause (A), (B), (C), and/or (D) of this Section 4.01(g)(2); or (3) is in violation of any obligation to maintain appropriate internal controls as required by the governing laws of the jurisdiction of such Person as are necessary to ensure compliance with the economic sanctions, anti-money laundering and anti-corruption laws of the United States and the jurisdiction where the Person resides, is domiciled or has its principal place of business. 4) Section 4.02(b) is deleted and replaced with the following:

Economic Sanctions, Anti-Money Laundering and Anti-Corruption. None of Borrower(1) Each Borrower Entity, any GuarantorIdentified Party, any Key PrincipalSteadfast REIT Holdings, or any Principal, nor to Borrower’s knowledge, its general partners, managing members, managers (if non-member managed)LLC, or any Person owning Controlled by Borrower Entity that also has a direct or controlling indirect Ownership Interest in any of them: (1) is Borrower Entity shall remain in violation of: (A) compliance with any applicable anti-money laundering laws, civil or criminal laws or regulations (including those contained in the Bank Secrecy Act; (Brequiring internal controls) any applicable economic sanction laws administered by OFAC intended to prohibit, prevent, or by regulate money laundering, drug trafficking, terrorism, or corruption, of the United States Department of State; or (C) any applicable anti-drug traffickingand the jurisdiction where the Mortgaged Property is located or where the Person resides, anti-terrorismis domiciled, or anti-corruption laws, civil or criminal; orhas its principal place of business. (2) is At no time shall any Borrower Entity, any Identified Party, Steadfast REIT Holdings, LLC, or any Person Controlled by Borrower Entity that also has a direct or indirect Ownership Interest in any Borrower Entity, be a Person: (A) that is charged with, or has reason to believe that he, she or it is under investigation for, against whom proceedings are pending for any alleged violation of any such lawslaws described in Section 4.02(b)(1) (Borrower Status – Covenants – Economic Sanctions, Anti-Money Laundering, and Anti-Corruption); (B) that has been convicted of any violation of, has been subject to civil penalties or Economic Sanctions pursuant to, or had any of its property seized or forfeited under under, any such laws;laws described in Section 4.02(b)(1) (Borrower Status – Covenants – Economic Sanctions, Anti-Money Laundering, and Anti-Corruption); or (C) named on the list of “Specially Designated Nationals or Blocked Persons” maintained by OFAC (or any successor United States government office or list), or any similar list maintained by the United States Department of State (or any successor United States government office or list); (D) with whom any United States Person, any entity organized under the laws of the United States or its constituent states or territories, or any entity, regardless of where organized, having its principal place of business within the United States or any of its territories, is a Sanctioned Person or is otherwise prohibited from transacting business of the type contemplated by this Loan Master Agreement and the other Loan Documents under any other applicable law; or (E) that is owned, controlled by, or affiliated with any Person identified in clause (A), (B), (C), and/or (D) of this Section 4.01(g)(2); orApplicable Law. (3) is Borrower, Guarantor, and Key Principal shall at all times remain in violation of any obligation to maintain appropriate internal controls as required by the governing laws of the jurisdiction of such Person as are necessary to ensure compliance with the economic sanctions, anti-money laundering any applicable Economic Sanctions laws and anti-corruption laws of the United States and the jurisdiction where the Person resides, is domiciled or has its principal place of businessregulations.

Economic Sanctions, Anti-Money Laundering and Anti-Corruption. (1) None of Borrower, any Guarantor, Guarantor or any Key Principal, or any Principal, nor to Borrower’s 's knowledge, its general partners, managing members, managers (if non-member managed), or any Person owning or controlling a Controlling Interest in any of them: (1) them is in violation of: (A) any applicable anti-money laundering laws, including those contained in the Bank Secrecy Act;; and (B) any applicable economic sanction laws administered by OFAC or by the United States Department of State; or (C) any applicable anti-drug trafficking, anti-terrorism, or anti-anti- corruption laws, civil or criminal; or. (2) None of Borrower, any Guarantor, any Key Principal, or any Principal, nor to Borrower's knowledge, its general partners, managing members, managers (if non- member managed), or any Person owning a Controlling Interest in any of them is a Person: (A) that is charged with, or has reason to believe that he, she or it is under investigation for, any violation of any such laws; (B) that has been convicted of any violation of, has been subject to civil penalties pursuant to, or had any of its property seized or forfeited under under, any such laws; (C) named on the list of “Specially Designated Nationals or Blocked Persons” maintained by OFAC (or any successor United States government office or list), or any similar list maintained by the United States Department of State (or any successor United States government office or list); (D) with whom any United States Person, any entity organized under the laws of the United States or its constituent states or territories, or any entity, regardless of where organized, having its principal place of business within the United States or any of its territories, is prohibited from transacting business of the type contemplated by this Loan Agreement and the other Loan Documents under any other applicable law; or (E) that is owned, controlled by, or affiliated with any Person identified in clause (A), (B), (C), and/or (D) of this Section 4.01(g)(2); or[Intentionally Deleted]. (3) None of Borrower, any Guarantor, any Key Principal, nor to Borrower's knowledge, its general partners, managing members, managers (if non-member managed), or any Person owning a Controlling Interest in any of them is in violation of any obligation to maintain appropriate internal controls as required by the governing laws of the jurisdiction of such Person as are necessary to ensure compliance with the economic sanctions, anti-money laundering laundering, and anti-corruption laws of the United States and the jurisdiction where the Person resides, is domiciled or has its principal place of business. (4) Borrower, Guarantor and Key Principal are in compliance with all applicable economic sanctions laws administered by OFAC, the United States Department of State, or the United States Department of Commerce.

Economic Sanctions, Anti-Money Laundering and Anti-Corruption. (1) None of Borrower, any Guarantor, or any Key Principal, or any Principal, nor to Borrower’s knowledge, its general partners, managing members, managers (if non-member managed), or any Person owning or controlling having a Controlling Interest in any of them: (1) them is in violation of: (A) any applicable anti-money laundering laws, including those contained in the Bank Secrecy Act;; and (B) any applicable economic sanction laws administered by OFAC or by the United States Department of State; or (C) any applicable anti-drug trafficking, anti-terrorism, or anti-corruption laws, civil or criminal; or. (2) None of Borrower, any Guarantor, any Key Principal, nor to Borrower’s knowledge, any Person having a Controlling Interest in any of them is a Person: (A) that is charged with, or has reason to believe that he, she or it is under investigation for, any violation of any such laws; (B) that has been convicted of any violation of, has been subject to civil penalties pursuant to, or had any of its property seized or forfeited under any such laws; (C) named on the list of “Specially Designated Nationals or Blocked Persons” maintained by OFAC (or any successor United States government office or list), or any similar list maintained by the United States Department of State (or any successor United States government office or list); (D) with whom any United States Person, any entity organized under the laws of the United States or its constituent states or territories, or any entity, regardless of where organized, having its principal place of business within the United States or any of its territories, is prohibited from transacting business of the type contemplated by this Loan Agreement and the other Loan Documents under any other applicable law; or; (ED) that is owned, controlled by, or affiliated with any Person identified in clause (A), (B), ) and/or (C), and/or (D) of this Section 4.01(g)(2); or. (3) None of Borrower, any Guarantor, any Key Principal, nor to Borrower’s knowledge, any Person having a Controlling Interest in any of them, is in violation of any obligation to maintain appropriate internal controls as required by the governing laws of the jurisdiction of such Person as are necessary to ensure compliance with the economic sanctions, anti-money laundering and anti-corruption laws of the United States and the jurisdiction where the Person resides, is domiciled or has its principal place of business. (4) Borrower, Guarantor and Key Principal are in compliance with all applicable economic sanctions laws administered by OFAC, the United States Department of State, or the United States Department of Commerce.

Economic Sanctions, Anti-Money Laundering and Anti-Corruption. (a) None of the Borrower or any of its Subsidiaries nor, to the knowledge of the Borrower, any Guarantordirector, officer, employee or controlled Affiliate of the Borrower or any Key Principalof its Subsidiaries is a Person that is, or is owned or controlled by Persons that are: (i) the subject of any Principalsanctions administered or enforced by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) or the U.S. State Department, nor the United Nations Security Council, the European Union or Her Majesty’s Treasury (collectively, “Sanctions”), or (ii) located, organized or resident in a country or territory that is, or whose government is, the subject of Sanctions (including, as of the date of this Agreement, Crimea, Cuba, Iran, North Korea and Syria). The Borrower, its Subsidiaries and, to the knowledge of the Borrower, their respective directors, officers, employees and agents are and have been in compliance in all material respects with all applicable Sanctions. The Borrower will not, directly or, to the Borrower’s knowledge, its general partnersindirectly, managing members, managers (if non-member managed)use the proceeds of the Loans, or lend, contribute or otherwise make available such proceeds to any subsidiary, joint venture partner or other Person owning to fund any activities or controlling business of or with any Person, or in any country or territory, that, at the time of such funding, is, or whose government is, the subject of Sanctions. (b) None of the Borrower or any of them: its Subsidiaries nor, to the knowledge of the Borrower, any director, officer, employee or agent of the Borrower or any of its Subsidiaries has taken any action, directly or indirectly, that would result in a material violation by such persons of the Foreign Corrupt Practices Act of 1977, as amended, and the rules and regulations thereunder (1the “FCPA”) is or any other applicable anti-corruption law. No part of the proceeds of the Loans will be used, directly or to the Borrower’s knowledge, indirectly, for any payments to any governmental official or employee, political party, official of a political party, candidate for political office, or anyone else acting in an official capacity in violation of: (A) of the FCPA or any other anti-corruption law. The Borrower and its Subsidiaries are in compliance, in all material respects, with the Act and all other applicable anti-money laundering laws, including those contained in the Bank Secrecy Act;and counter-terrorist financing laws and regulations. (Bc) any applicable economic sanction laws administered by OFAC or by the United States Department of State; or (C) any applicable anti-drug trafficking, anti-terrorism, or anti-corruption laws, civil or criminal; or (2) is a Person: (A) that is charged with, or has reason to believe that he, she or it is under investigation for, any violation of any such laws; (B) that has been convicted of any violation of, has been subject to civil penalties pursuant to, or had any of The Borrower and its property seized or forfeited under any such laws; (C) named on the list of “Specially Designated Nationals or Blocked Persons” maintained by OFAC (or any successor United States government office or list), or any similar list maintained by the United States Department of State (or any successor United States government office or list); (D) with whom any United States Person, any entity organized under the laws of the United States or its constituent states or territories, or any entity, regardless of where organized, having its principal place of business within the United States or any of its territories, is prohibited from transacting business of the type contemplated by this Loan Agreement Subsidiaries have instituted and the other Loan Documents under any other applicable law; or (E) that is owned, controlled by, or affiliated with any Person identified in clause (A), (B), (C), and/or (D) of this Section 4.01(g)(2); or (3) is in violation of any obligation to maintain appropriate internal controls as required by the governing laws of the jurisdiction of such Person as are necessary policies and procedures designed to ensure compliance with the economic sanctionsall applicable Sanctions, anti-corruption laws and anti-money laundering laws and anti-corruption laws of the United States and the jurisdiction where the Person resides, is domiciled or has its principal place of businessregulations.