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. 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. 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 that an item listed on the Exception Report is not suspicious, it will document its findings. Any item which the Transfer Agent, in is 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, if it deems appropriate will report such activity to the Risk and Co...
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. (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:
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. 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. Ultimus will maintain and implement procedures reasonably designed to assist the Trust 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 Trust and its shareholders during Ultimus’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 Ultimus will deliver a suspicious activity referral to the Trust.
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.).
Suspicious Activity Monitoring. BNY Mellon as agent of the Fund will engage in a commercially reasonable monitoring of activities occurring with respect to the Fund during BNY Mellon’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 BNY Mellon will deliver a suspicious activity referral to the Fund.
