Common use of Review and Evaluation Clause in Contracts

Review and Evaluation. Before a Fund delegates any aspect of the implementation of this AML Program to a Service Provider, and no less frequently than annually thereafter, the AML Compliance Officer shall review and evaluate the Service Provider's anti-money laundering program as it relates to functions delegated to the Service Provider by the Fund. Each such Service Provider to whom a Fund delegates any aspect of the implementation and operation of this AML Program must have adopted and implemented an anti-money laundering program that complies with all laws, regulations and regulatory guidance applicable to the Fund and such Service Provider as it relates to functions delegated to the Service Provider by the Fund, and should include, at a minimum (to the extent relevant): * know-your-customer policies; * due diligence policies for correspondent accounts for foreign financial institutions and for private banking accounts for non- U.S. persons; * detecting and reporting suspicious activity; * monitoring accounts and identifying high-risk accounts; * a designated compliance officer or committee with responsibility for implementing the anti-money laundering program; * employee training; * an independent audit function; and * recordkeeping requirements. In conducting a review and evaluation of each Service Provider's anti-money laundering program, the AML Compliance Officer shall obtain and consider: * a copy of the Service Provider's anti-money laundering program and any material amendment thereto promptly after the adoption of any such amendment; * a copy of any deficiency letter sent by federal examination authorities concerning the Service Provider's anti-money laundering program; and * no less frequently than annually, a report on the Service Provider's anti-money laundering program that includes a certification to the Fund concerning the Service Provider's implementation of, and ongoing compliance with, its anti-money laundering program and a copy of any audit report prepared with respect to Service Provider's anti-money laundering program. The AML Compliance Officer shall retain records memorializing this evaluation.

Review and Evaluation. Before a Fund delegates any aspect of the implementation of this AML Program to a Service Provider, and no less frequently than annually thereafter, the AML Compliance Officer shall review and evaluate the Service Provider's anti-money laundering program as it relates to functions delegated to the Service Provider by the Fund. Each such Service Provider to whom a Fund delegates any aspect of the implementation and operation of this AML Program must have adopted and implemented an anti-money laundering program that complies with all laws, regulations and regulatory guidance applicable to the Fund and such Service Provider as it relates to functions delegated to the Service Provider by the Fund, and should include, at a minimum (to the extent relevant): * know-your-customer policies; * due diligence policies for correspondent accounts for foreign financial institutions and for private banking accounts for non- U.S. persons; * detecting and reporting suspicious activity; * monitoring accounts and identifying high-risk accounts; * a designated compliance officer or committee with responsibility for implementing the anti-money laundering program; * employee training; * an independent audit function; and * recordkeeping requirements. In conducting a review and evaluation of each Service Provider's anti-anti- money laundering program, the AML Compliance Officer shall obtain and consider: * a copy of the Service Provider's anti-money laundering program and any material amendment thereto promptly after the adoption of any such amendment; * a copy of any deficiency letter sent by federal examination authorities concerning the Service Provider's anti-money laundering program; and * no less frequently than annually, a report on the Service Provider's anti-money laundering program that includes a certification to the Fund concerning the Service Provider's implementation of, and ongoing compliance with, its anti-money laundering program and a copy of any audit report prepared with respect to Service Provider's anti-money laundering program. The AML Compliance Officer shall retain records memorializing this evaluation.