Common use of Surveillance and Suspicious Activity Reporting Clause in Contracts

Surveillance and Suspicious Activity Reporting. (a) Master Account Holder shall conduct surveillance of the activity in the Subsidiary Accounts including, without limitation, reviewing trading, deposits, withdrawals, transfers of funds and other account activity for the purpose of detecting suspicious transactions or other activity that may involve money laundering, terrorist activity or other illegal conduct. (b) Master Account Holder shall notify IBAU's AML Compliance Officer regarding any account activity Master Account Holder knows or has reason to suspect: involves funds related to money laundering, terrorist activity or any other illegal conduct; is intended or conducted in order to hide or disguise funds or assets derived from illegal activity; is designed to evade laws or regulations; involves the use of IBAU or the Master Account Holder to facilitate criminal activity; is not legitimate, has no business or apparent purpose or is not the sort of transactions in which the particular client would normally be expected to engage (and there is no reasonable explanation therefor); is otherwise suspicious; or could support the filing of a suspicious transaction report ("STR"). Such notice shall be provided by the Master Account Holder as soon as practical after identifying the activity and, in any event, prior to filing an STR. Master Account Holder shall provide IBAU with copies of all STRs and other communications it files with respect to the Subsidiary Accounts, unless prohibited by law. Master Account Holder shall provide IBAU with any other information or documentation regarding the above-referenced account activity, the responsible client or related persons that IBAU, in its sole discretion, believes is necessary or appropriate to fulfill its obligations and shall take any action that IBAU may request in connection with the such activity, whether the activity was detected by Master Account Holder or IBAU. (c) IBAU reserves the right to monitor the activity in the Subsidiary Accounts and to make and file such suspicious transaction or other reports as it deems necessary or appropriate. Master Account Holder recognizes that, by conducting such surveillance and filing such reports, XXXX does not thereby assume any responsibility of the Master Account Holder for conducting surveillance of the activity Subsidiary Accounts nor to report any suspicious activity therein.

Surveillance and Suspicious Activity Reporting. (a) Master Omnibus Account Holder shall conduct surveillance of the activity in the Subsidiary Accounts its clients activities including, without limitation, reviewing trading, deposits, withdrawals, transfers of funds and other account activity for the purpose of detecting suspicious transactions or other activity that may involve money laundering, terrorist activity or other illegal conduct. (b) Master Omnibus Account Holder shall notify IBAU's AML Compliance Officer regarding any account activity Master Omnibus Account Holder knows or has reason to suspect: involves funds related to money laundering, terrorist activity or any other illegal conduct; is intended or conducted in order to hide or disguise funds or assets derived from illegal activity; is designed to evade laws or regulations; involves the use of IBAU or the Master Omnibus Account Holder to facilitate criminal activity; is not legitimate, has no business or apparent purpose or is not the sort of transactions in which the particular client would normally be expected to engage (and there is no reasonable explanation therefor); is otherwise suspicious; or could support the filing of a suspicious transaction matter report ("STRSMR"). Such notice shall be provided by the Master Omnibus Account Holder as soon as practical after identifying the activity and, in any event, prior to filing an STRSMR. Master Omnibus Account Holder shall provide IBAU with copies of all STRs SMRs and other communications it files with respect to the Subsidiary Accountsits clients, unless prohibited by law. Master Omnibus Account Holder shall provide IBAU with any other information or documentation regarding the above-referenced account activity, the responsible client or related persons that IBAU, in its sole discretion, believes is necessary or appropriate to fulfill its obligations and shall take any action that IBAU may request in connection with the such activity, whether the activity was detected by Master Omnibus Account Holder or IBAU. (c) IBAU reserves the right to monitor the activity in the Subsidiary Accounts and to make and file such suspicious transaction or other reports as it deems necessary or appropriate. Master Account Holder recognizes that, by conducting such surveillance and filing such reports, XXXX does not thereby assume any responsibility of the Master Account Holder for conducting surveillance of the activity Subsidiary Accounts nor to report any suspicious activity therein.

Surveillance and Suspicious Activity Reporting. (a) Master Account Holder The Introducing Broker shall conduct surveillance of the activity in the Subsidiary Fully Disclosed Accounts including, without limitation, reviewing trading, deposits, withdrawals, transfers of funds and other account activity for the purpose of detecting suspicious transactions or other account activity that may involve money laundering, terrorist financing activity or other illegal conduct. (b) Master Account Holder . The Introducing Broker shall notify IBAUIBIE's AML Compliance Officer regarding any account activity Master Account Holder the Introducing Broker knows or has reason to suspect: involves funds related to money laundering, terrorist financing activity or any other illegal conduct; is intended or conducted in order to hide or disguise funds or assets derived from illegal activity; is designed to evade laws or regulations; involves the use of IBAU IBIE or the Master Account Holder Introducing Broker to facilitate criminal activity; is not legitimate, has no business or apparent purpose or is not the sort of transactions in which the particular client Client would normally be expected to engage (and there is no reasonable explanation therefor); is otherwise suspicious; or could support the filing of a suspicious transaction activity report ("STRSAR")) of any kind. Such notice shall be provided by the Master Account Holder Introducing Broker as soon as practical after identifying the activity and, in any event, prior to filing an STRa SAR. Master Account Holder The Introducing Broker shall communicate with IBIE about the account activity for the purposes of sharing information about the activity and shall provide IBAU with copies of all STRs and other communications it files with respect to the Subsidiary Accounts, unless prohibited by law. Master Account Holder shall provide IBAU IBIE with any other information or documentation regarding the above-referenced account activity, the responsible client Client or related persons that IBAUIBIE, in its sole discretion, believes is necessary or appropriate to fulfill fulfil its obligations obligations. The Introducing Broker shall provide IBIE with copies of all SARs and other communications it files with any exchange or governmental, regulatory or self- regulatory body regarding the activity. The Introducing Broker shall take any action that IBAU IBIE may request in connection with the such activity, whether the activity was detected by Master Account Holder the Introducing Broker, IBIE or IBAUboth. (c) IBAU reserves the right to monitor the activity in the Subsidiary Accounts and to make and file such suspicious transaction or other reports as it deems necessary or appropriate. Master Account Holder recognizes that, by conducting such surveillance and filing such reports, XXXX does not thereby assume any responsibility of the Master Account Holder for conducting surveillance of the activity Subsidiary Accounts nor to report any suspicious activity therein.

Surveillance and Suspicious Activity Reporting. (a) Master Account Holder a. Introducing Broker shall conduct surveillance of the activity in the Subsidiary Accounts including, without limitation, reviewing trading, deposits, withdrawals, transfers of funds and other account activity for the purpose of detecting suspicious transactions or other account activity that may involve money laundering, terrorist activity or other illegal conduct. (b) Master Account Holder b. Introducing Broker shall notify IBAUIBUK's AML Compliance Officer regarding any account activity Master Account Holder Introducing Broker knows or has reason to suspect: involves funds related to money laundering, terrorist activity or any other illegal conduct; is intended or conducted in order to hide or disguise funds or assets derived from illegal activity; is designed to evade laws or regulations; involves the use of IBAU IBUK or the Master Account Holder Introducing Broker to facilitate criminal activity; is not legitimate, has no business or apparent purpose or is not the sort of transactions in which the particular client customer would normally be expected to engage (and there is no reasonable explanation therefor); is otherwise suspicious; or could support the filing of a suspicious transaction activity report ("STRSAR")) of any kind. Such notice shall be provided by the Master Account Holder Introducing Broker as soon as practical after identifying the activity and, in any event, prior to filing an STRSAR. Master Account Holder Introducing Broker shall communicate with IBUK about the account activity for the purposes of sharing information about the activity and shall provide IBAU with copies of all STRs and other communications it files with respect to the Subsidiary Accounts, unless prohibited by law. Master Account Holder shall provide IBAU IBUK with any other information or documentation regarding the above-referenced account activity, the responsible client customer or related persons that IBAUIBUK, in its sole discretion, believes is necessary or appropriate to fulfill its obligations obligations. Introducing Broker shall provide IBUK with copies of all SARs and other communications it files with any exchange or governmental, regulatory or self-regulatory body regarding the activity. Introducing Broker shall take any action that IBAU IBUK may request in connection with the such activity, whether the activity was detected by Master Account Holder Introducing Broker or IBAUIBUK. (c) IBAU reserves the right to monitor the activity in the Subsidiary Accounts and to make and file such suspicious transaction or other reports as it deems necessary or appropriate. Master Account Holder recognizes that, by conducting such surveillance and filing such reports, XXXX does not thereby assume any responsibility of the Master Account Holder for conducting surveillance of the activity Subsidiary Accounts nor to report any suspicious activity therein.