Foreign Account Due Diligence. (a) To help the Fund comply with its requirements to establish and implement a due diligence program for “foreign financial institution” accounts (which the Fund is required to have under regulations issued under Section 312 of the USA PATRIOT Act), PNC will do the following: (i) Implement and operate a due diligence program that includes appropriate, specific, risk-based policies, procedures and controls that are reasonably designed to enable the Fund to detect and report, on an ongoing basis, any known or suspected money laundering activity conducted through or involving any correspondent account established, maintained, administered or managed by the Fund for a “foreign financial institution” (as defined in 31 CFR 103.175(h)) (“Foreign Financial Institution”); (ii) Conduct due diligence to identify, detect and prohibit any new Foreign Financial Institution accounts (other than those allowed by written exception from the Fund’s MLRO)
Appears in 9 contracts
Samples: Transfer Agency Services Agreement (Ing Variable Portfolios Inc), Transfer Agency Services Agreement (ING Separate Portfolios Trust), Transfer Agency Services Agreement (Ing Partners Inc)
