Common use of Provision of AML Services Clause in Contracts

Provision of AML Services. Xxxxxxx shall provide AML Services and undertake to administer and operate, in accordance with the requirements of the Bank Secrecy Act, as amended by the USA Patriot Act, its implementing regulations, and applicable rules adopted thereunder, the following aspects of the Funds’ AML Program including, but not limited to: (i) Monitoring and reporting of receipt of cash or cash equivalents; (ii) Suspicious activity monitoring and reporting; (iii) Comparisons with governmental lists, including the U.S. Treasury Department’s Office of Foreign Asset Control (“OFAC”) “Specially Designated National and Blocked Persons List” (“SDN List”); (iv) AML education for appropriate employees of the Funds, as requested by the Funds, and their service providers, including certain Xxxxxxx personnel; (v) Verifications that registered representatives (and insurance representatives) have received AML training at affiliated and unaffiliated broker-dealers; (vi) Reporting and recordkeeping requirements associated with the aforementioned services; and (vii) Performance of Customer Identification Program in association with Xxxxxxx’x Anti-Money Laundering Policy and the USA Patriot Act. Xxxxxxx agrees to perform such aspects on behalf of the Funds AML Program consistent with Xxxxxxx’x AML obligations as an insurance company.

Provision of AML Services. Xxxxxxx shall provide AML Services and undertake to administer and operate, in accordance with the requirements of the Bank Secrecy Act, as amended by the USA Patriot Act, its implementing regulations, and applicable rules adopted thereunder, the following aspects of the Funds’ Trust’s AML Program including, but not limited to: (i) Monitoring and reporting of receipt of cash or cash equivalents; (ii) Suspicious activity monitoring and reporting; (iii) Comparisons with governmental lists, including the U.S. Treasury Department’s Office of Foreign Asset Control (“OFAC”) “Specially Designated National and Blocked Persons List” (“SDN List”); (iv) AML education for appropriate employees of the FundsTrust, as requested by the FundsTrust, and their service providers, including certain Xxxxxxx personnel; (v) Verifications that registered representatives (and insurance representatives) have received AML training at affiliated and unaffiliated broker-dealers; (vi) Reporting and recordkeeping requirements associated with the aforementioned services; and (vii) Performance of Customer Identification Program in association with Xxxxxxx’x Anti-Money Laundering Policy and the USA Patriot Act. Xxxxxxx agrees to perform such aspects on behalf of the Funds Trust AML Program consistent with Xxxxxxx’x AML obligations as an insurance company.