Sanctions Screening. The Bank, on behalf of the Transfer Agent, shall screen new and existing Authorized Participants, UBOs and Controlling Parties against sanction-related lists promulgated by the United States, the European Union, and the United Nations. The Bank reserves the right to screen new and existing Authorized Participants, UBOs and Controlling Parties against such other sanction-related lists as may be required by the Bank’s AML and Sanctions Program from time to time. The Fund acknowledges that the Bank and the Transfer Agent shall have no obligation to accept any Authorized Participant’s order for Creation Units, and shall have the right to block, freeze or reject any Authorized Participant’s order or account, as applicable, in order for the Bank and/or the Transfer Agent to meet its legal and/or internal compliance requirements. In the event that an Authorized Participant’s order or account is blocked, frozen or rejected, the Transfer Agent shall promptly inform the Designated Contact of the circumstances that lead to the block, freeze or rejection.
Sanctions Screening. The Bank, on behalf of the Transfer Agent, shall screen new and existing Fund Investors, UBOs and Controlling Parties against sanction-related lists promulgated by the United States, the European Union, and the United Nations. The Bank reserves the right to screen new and existing Fund Investors, UBOs and Controlling Parties against such other sanction-related lists as may be required by the Bank’s AML and Sanctions Program from time to time. The Fund acknowledges that the Bank and the Transfer Agent shall have no obligation to accept any Fund Investor’s subscription, and shall have the right to block, freeze or reject any Fund Investor’s subscription or account, as applicable, in order for the Bank and/or the Transfer Agent to meet its legal and/or internal compliance requirements. In the event that a Fund Investor’s subscription is blocked, frozen or rejected, the Transfer Agent shall promptly inform the Designated Contact of the circumstances that lead to the block, freeze or rejection.
Sanctions Screening. The Bank, on behalf of the Transfer Agent and the Funds, shall, before opening an account for a new Authorized Participant and periodically thereafter, screen Authorized Participants against sanction-related lists promulgated by the United States, the European Union, and the United Nations, including, but not limited to, those issued/maintained by the Office of Foreign Asset Control (“OFAC”) of the United States Department of the Treasury. The Bank reserves the right to screen new and existing Authorized Participants against such other sanction-related lists as may be required by the Bank’s AML and Sanctions Program from time to time. The Bank and the Transfer Agent shall block, freeze or reject any Authorized Participant’s order or account in the event that a new or existing Authorized Participant matches a name contained on one of the foregoing sanctions lists and the Bank cannot resolve such match in accordance with the Transfer Agent’s AML Procedures. The Fund acknowledges that the Bank and the Transfer Agent shall have no obligation to accept any Authorized Participant’s order for Creation Units and shall have the right to block, freeze or reject any Authorized Participant’s order or account, as applicable, in order for the Bank and/or the Transfer Agent to meet its legal and/or internal compliance requirements. In the event that an Authorized Participant’s order or account is blocked, frozen or rejected, the Transfer Agent shall promptly inform the Fund’s AML Officer, as identified to the Transfer Agent by the Fund from time to time (the “Designated Contact”), of the circumstances that led to the block, freeze or rejection.
Sanctions Screening. The Seller shall forthwith upon the execution of this Agreement by the parties direct in writing (such direction being in the Agreed Form) the CEO and the CFO of the Group to procure the provision to the Purchaser of the names and locations of clients of the Group who the Group are aware are clients with overseas operations, clients in sanctioned countries, clients with marine energy or aviation business and clients in such other classes of business which in the opinion of the Purchaser, acting reasonably, are high risk for the purposes of the Purchaser Group’s client and customer sanctions screening process. The Purchaser shall ensure that all such information is kept strictly confidential and is only used for the purposes of the screening process and for no other purpose whatsoever. The Purchaser agrees and acknowledges that if the CEO and the CFO do not comply with any such direction or in the event any customer or client does not pass its screening process, this shall not give rise to any liability on the part of the Seller (or any other person or entity) nor will it entitle the Purchaser to terminate this Agreement pursuant to clause 3.9 or otherwise.
Sanctions Screening. School understands that Xxxxx will make reasonable inquiry into the prior conduct and sanctions imposed on School and School’s Students, including, but not limited to, review of the General Services Administration’s list of parties excluded from federal programs and the Department of Health and Human Services (DHHS)/Office of Inspector General (OIG) cumulative sanction report.
Sanctions Screening. School understands that Sharp will make reasonable inquiry into the prior conduct and sanctions imposed on School and School’s Students, including, but not limited to, review of the General Services Administration’s list of parties excluded from federal programs and the Department of Health and Human Services (DHHS)/Office of Inspector General (OIG) cumulative sanction report.
Sanctions Screening. Paymentech will perform sanctions screening of all prospective Merchants. If the screening indicates that the prospective or existing Merchant or its owner(s) are on a sanctions list, TP3 will research and provide additional demographic information, as may be requested by Paymentech, and will provide the results of such research to Paymentech within three (3) Business Days. TP3 shall ensure that a prospective Merchant listed on a sanctions list shall not be permitted to be a Merchant. In addition, if an existing Merchant is found on a sanctions list, Paymentech will notify TP3 and TP3 must terminate such Merchant within three (3) Business Days.
Sanctions Screening. The Bank, on behalf of the Transfer Agent, shall screen new and existing Company Investors, UBOs and Controlling Parties against sanction-related lists promulgated by the United States, the European Union, and the United Nations. The Bank reserves the right to screen new and existing Company Investors, UBOs and Controlling Parties against such other sanction-related lists as may be required by the Bank’s AML and Sanctions Program from time to time. The Company acknowledges that the Bank and the Transfer Agent shall have no obligation to accept any Company Investor’s subscription, and shall have the right to block, freeze or reject any Company Investor’s subscription or account, as applicable, in order for the Bank and/or the Transfer Agent to meet its legal and/or internal compliance requirements. In the event that a Company Investor’s subscription is blocked, frozen or rejected, the Transfer Agent shall Information Classification: Limited Access promptly inform the Designated Contact of the circumstances that lead to the block, freeze or rejection.
Sanctions Screening. The Bank, on behalf of the Transfer Agent, shall screen new and existing Trust Investors against sanction-related lists promulgated by the United States, the European Union, and the United Nations. The Bank reserves the right to screen new and existing Trust Investors against such other sanction-related lists as may be required by the Bank’s AML Program from time to time. The Trust acknowledges that the Bank and the Transfer Agent shall have no obligation to accept any Trust Investor’s subscription, and shall have the right to block, freeze, or reject any Trust Investor’s subscription or account, as applicable, in order for the Bank and/or the Transfer Agent to meet its legal and/or internal compliance requirements. In the event that a Trust Investor’s subscription is blocked, frozen, or rejected, the Transfer Agent shall promptly inform the Designated Contact of the circumstances that lead to the block, freeze, or rejection.
Sanctions Screening. The Bank, on behalf of the Transfer Agent, shall screen new and existing investors, UBOs and Controlling Parties against sanction-related lists promulgated by the United States, the European Union, and the United Nations. The Bank reserves the right to screen new and existing investors, UBOs and Controlling Parties against such other sanction-related lists as may be required by the Bank AML/Sanctions Program from time to time. The Funds acknowledge that Information Classification: Limited Access Information Classification: Limited Access the Bank and the Transfer Agent shall have no obligation to accept any investor’s subscription, and shall have the right to block, freeze, or reject any investor’s subscription or account, as applicable, in order for the Bank and/or the Transfer Agent to meet its legal and/or internal compliance requirements. In the event that an investor’s subscription or account is blocked, frozen, or rejected, the Transfer Agent shall promptly inform the Financial Crime Representative of the circumstances that lead to the block, freeze, or rejection. The Bank and Transfer Agent is aware of the Sanctions Laws and has implemented and will maintain and follow controls, policies and procedures reasonably designed to ensure compliance with Sanctions Laws applicable to it. The Bank acknowledges that the Funds are subject to Sanctions Laws applicable to them and that by entering into this Agreement the Funds have made the determination that the Funds will rely on the Bank and Transfer Agent to perform the AML/Sanctions Assistance Functions set forth in this Section 2.2(d) of this Agreement. As a result, the Bank and Transfer Agent will maintain controls, policies and procedures reasonably designed to ensure performance of its obligations herein. The Bank’s performance of the AML/Sanctions Assistance Functions under this Section 2.2(d) for the Funds does not relieve Funds of their regulatory responsibility for compliance with Sanctions Laws. Any and all names that result in a “true hit” against a sanctions list must be escalated to the Funds Financial Crime Representative. The Bank shall also promptly notify the Funds Financial Crime Representative of any actual violation of applicable Sanctions Laws in connection with the AML/Sanctions Assistance Functions performed for the Funds of which the Bank becomes aware. The Bank’s sanctions policies and procedures will be audited by the Bank’s external and internal auditors on a periodic basis.
