Suspicious Activity Monitoring. BNYM as agent of the Fund will engage in a commercially reasonable monitoring of activities occurring with respect to the Fund during BNYM’s performance of transaction processing and recordkeeping services and if in the course of such monitoring it determines that any of such activities could indicate the existence of suspicious activity and that an investigation of the potential suspicious activity is warranted, then BNYM will deliver a suspicious activity referral to the Fund.
Suspicious Activity Monitoring. BNYM will maintain and implement procedures reasonably designed to assist the Fund in complying with rules promulgated by FinCEN under the Bank Secrecy Act (31. C.F.R § 1024.320) with respect to the monitoring for suspicious activity that may occur in connection with the Fund and its shareholders during BNYM’s performance of transaction processing and recordkeeping services hereunder and if in the course of such monitoring it determines that any of such activities could indicate the existence of suspicious activity and that an investigation of the potential suspicious activity is warranted, then BNYM will deliver a suspicious activity referral to the Fund.
Suspicious Activity Monitoring. The Transfer Agent, for each participant account, will establish an activity pattern (the account “Profile”) based on its transactional history for the immediately preceding twelve-month period or such shorter period if the account has been established for less than a year. The Profile will be based upon the number of purchases and redemptions, as well as the average dollar amount of such purchase and redemptions during such period. Exchange transactions may or may not be a part of the Profile, as determined upon mutual agreement of the parties. The Profile shall not include other transactional activity including, but not limited to, dividends, share adjustments and stock splits. The Fund shall provide written approval of its acceptance of such Profiles. After the Profile has been approved by the Fund, it may be revised by State Street, without notice to the Fund, from time to time, to reflect the transactional history of the account during preceding months. On a daily basis, the Transfer Agent will input a file of the purchase, redemption, exchange, and transfer transactions on a participant account into its database in an effort to analyze and report any transaction (an “Exception Report’) that does not correspond to the established account Profile or, upon request by the Fund, upon rules established by the Fund (e.g. report on any transaction below a dollar minimum) and agreed upon by the Transfer Agent.
Suspicious Activity Monitoring. The Transfer Agent, for each shareholder account, will establish an activity pattern (the account "Profile") based on its transactional history for the immediately preceding twelve-month period or such shorter period if the account has been established for less than a year. The Profile will be based upon the number of purchases and redemptions, as well as the average dollar amount of such purchase and redemptions during such period. Exchange transactions may or may not be a part of the Profile, as determined by the Fund. The Profile shall not include other transactional activity including, but not limited to, dividends, share adjustments and stock splits. The Fund shall provide written approval of its acceptance of such Profiles.
Suspicious Activity Monitoring. BNYM will maintain and implement procedures reasonably designed to assist the Fund in complying with rules promulgated by FinCEN under the Bank Secrecy Act (31. C.F.R § 1024.320) with respect to the monitoring for suspicious activity that may occur in connection with the Fund and its shareholders during BNYM’s performance of transaction processing and recordkeeping services hereunder and if in the course of such monitoring it determines that any of such activities could indicate the existence of suspicious activity and that an investigation of the potential suspicious activity is warranted, then BNYM will deliver a suspicious activity referral to the Fund in a timely manner, with “timely” for purposes of this Section 3(b)(7) meaning within a commercially reasonable period following BNYM’s detection of the events and circumstances reasonably suspected to be suspicious activity and BNYM’s investigation of such events and circumstances, utilizing reasonably designed detection and investigative procedures.
Suspicious Activity Monitoring. (1) Within ninety (90) days of the date of this Agreement, the Board shall submit to the Assistant Deputy Comptroller, for a prior written determination of no supervisory objection, a revised suspicious activity monitoring program to ensure, pursuant to 12 C.F.R. § 163.180, the timely and appropriate identification and review of suspicious transaction activity, disposition of suspicious activity alerts, and filing of Suspicious Activity Reports (“SARs”). This program shall ensure the Bank operates in accordance with applicable law, including 12 C.F.R. § 163.180. At a minimum, the revisions must include:
(a) effective processes and staff to ensure identification, investigation, monitoring, and reporting of suspicious activity, which shall include implementing and adhering to a process to improve monitoring for the lending activities as specified in the Report of Examination dated as of March 31, 2018;
(b) an enhanced written BSA/AML risk assessment that timely and accurately identifies the BSA/AML risks posed to the Bank, and that includes:
(i) detailed analysis of BSA/AML risks in all products and services, and assignment of an inherent and residual risk to each;
(ii) detailed analysis of the effectiveness of the Bank’s risk management processes, including its system of internal controls, and identification of any gaps or weaknesses when determining residual risk; and
(iii) revised scoring for low-, moderate-, and high-risk to ensure risk ratings are appropriately stratified;
(c) revised policies and procedures to require business line referrals of suspicious activity to the BSA department and ensure that internal referral processes are consistently followed. The policies and procedures shall include requirements for:
(i) consistent documentation and tracking of business line referrals, with a case created for each referral in the Bank’s suspicious activity monitoring system; and
(ii) training for all employees, including quality control personnel and fraud investigators, regarding the internal process for referring suspicious activity; and
(d) a sufficient secondary quality assurance review process to ensure that disposition of suspicious activity alerts and SAR decision-making and filing are working effectively.
(2) No later than the next Board meeting following the receipt of the Assistant Deputy Comptroller’s written determination of no supervisory objection, the Board shall adopt, and management shall immediately implement and thereafter ensure adhere...
Suspicious Activity Monitoring. Each Fund and Service Provider to whom suspicious activity monitoring and reporting is delegated will be vigilant with respect to identifying any potentially suspicious activity. What Constitutes Suspicious Activity. Each Fund (and Service Provider to whom monitoring is delegated) will monitor for any purchase of at least $5,000.00 by, at, or through the Fund, involving an account with a balance below $5,000.00, and which the Fund (or the relevant Service Provider) knows, suspects, or has reason to suspect: • involves funds derived from illegal activity or is intended or conducted in order to hide or disguise funds or assets derived from illegal activity (including without limitation the ownership, nature, source, location, or control of such funds or assets) as part of a plan to violate or evade any federal law or regulation or to avoid any transaction reporting requirement under federal law or regulation; • is designed, whether through structuring or other means, to evade any requirements of any regulations promulgated under the BSA;
Suspicious Activity Monitoring. The Transfer Agent, for each shareholder account, will establish an activity pattern (the account "Profile") based on its transactional history for the immediately preceding twelve month time period or such shorter period if the account has been established for less than a year. The Profile will be based upon the number of purchases and redemptions, as well as the average dollar amount of such purchase and redemptions during such period. Exchange transactions may or may not be a part of the Profile, as determined by the Fund. The Profile shall not include other transactional activity including, but not limited to, dividends, share adjustments and stock splits. The Fund shall provide written approval of their acceptance of such Profiles. On a daily basis, the Transfer Agent will input a file of the purchase, redemption, exchange, and transfer transactions on a shareholder account into its database in an effort to analyze and report any transaction (an "Exception Report') that does not correspond to the established account Profile or, upon request by Fund, upon rules established by Fund (e.g. report on any transaction below a dollar minimum) and agreed upon by the Transfer Agent. The Transfer Agent will review each Exception Report produced by the database. If the Transfer Agent, upon review of the information available to it, determines an item listed on the Exception Report is not suspicious, it will document its findings. Any item which the Transfer Agent, in its reasonable opinion, determines is or may be suspicious will be reported to the Fund. Upon receipt of such notice, the Fund shall promptly provide any additional information which it would like the Transfer Agent to consider. Upon review of such additional information, the Transfer Agent may determine that the item is not suspicious in nature, in which case the Transfer Agent will report its findings to the Fund. If, however, the Transfer Agent cannot, in its sole judgment, determine the nature/cause of the suspicious transaction, the Transfer Agent will consider the item to be "suspicious" in nature and notify the Fund, unless prohibited by applicable law, rule or regulation. The Transfer Agent may file the appropriate report(s) on its own behalf with the applicable regulators and comply with instructions of appropriate regulator(s) which may include, without limitation, freezing the account and its assets, refusing to add an authorized signer or beneficiary to the account, and/or closing the acc...
Suspicious Activity Monitoring. State Street shall assist the Trust in monitoring Accounts for Suspicious Activity (as defined in Part V below) by performing the Procedures set forth in this Part IV. To facilitate the monitoring of Suspicious Activity, State Street shall establish for each Account an activity profile (the “Profile”) based on the transactional history of the Account for the immediately preceding twelve month time period or such shorter period if the Account has been established for less than a year. The Profile will be based upon the number of purchase, redemption, exchange and transfer transactions as well as the average dollar amount of such purchases, redemptions, exchanges and transfers during such period. The Profile shall not include other types of transactional activity (e.g., dividends, share adjustments and stock splits). Each initial Profile shall be approved in writing by the Trust or an authorized employee of Xxxxxx Xxxxxx, Inc. The Trust understands and acknowledges that each Profile may change from time to time automatically to reflect additional Account activity and experience and to improve the efficacy of the Profile. If, in State Street’s opinion, the Profile is not as effective as it could be in establishing account activity for purposes of monitoring Suspicious Activity on behalf of the Trust, State Street may revise the Profile and not subject such revised Profile to any automatic changes; in which case State Street shall so notify the Trust and the Profile, as revised, shall not change except as mutually agreed upon by the parties in writing. On a daily basis, State Street will input the purchase, redemption, exchange, and transfer transactions on each Account into its database to identify any transaction that does not correspond to the established Account Profile or, upon request by Trust, rules agreed to by the parties. With respect to each newly established Account, State Street will review transactions in the Account for thirty (30) days following the initial deposit into such Account to determine whether any such transaction or transactions, in its reasonable discretion, is or may be Suspicious Activity. State Street shall cause its employees involved in monitoring Suspicious Activity on behalf of the Trust to participate in ongoing training on the detection of Suspicious Activity.
Suspicious Activity Monitoring. BNYM as agent of the Fund will engage in a commercially reasonable monitoring of activities occurring with respect to the Fund during BNYM’s performance of transaction processing and recordkeeping services, including, but not limited to, a review of incoming and outgoing wire activity and other transactions to detect the suspicious movement of monies, and if in the course of such monitoring it determines that any of such activities could indicate the existence of suspicious activity and that an investigation of the potential suspicious activity is warranted, then BNYM will deliver a suspicious activity referral to the Fund. BNYM will comply with restrictions on payment methods accepted for purchase of Fund shares (e.g., no transactions in currency, third-party check restrictions, etc.).
