Common use of Transaction Monitoring and Suspicious Activity Reporting Clause in Contracts

Transaction Monitoring and Suspicious Activity Reporting. The Bank shall monitor transactions in customer accounts using a risk-based approach. The Bank shall use the definitions provided in the applicable rules and regulations promulgated under the Bank Secrecy Act to determine what activity may be suspicious. Any suspicious activity identified shall be reported to the Bank’s AML Compliance Officer who shall provide the applicable Fund’s AML Compliance Officer with all available information related to the activity in question. A Fund’s AML Compliance Officer shall be responsible for determining whether to file a Suspicious Activity Report (“SAR”) on behalf of the Fund and for the completion of any such filing. If appropriate, the Bank’s AML Compliance Officer will then ensure a SAR is properly filed on behalf of the Bank. Each party will ensure it has appropriate section 314(b) certifications on file to permit such sharing of information.

Transaction Monitoring and Suspicious Activity Reporting. The Bank shall maintain internal control procedures to monitor transactions in customer Authorized Participant accounts using a risk-based approach. The Bank shall use the definitions provided in the applicable rules and regulations promulgated under the Bank Secrecy Act to determine what activity may be suspicious. Any suspicious activity identified shall be reported to the Bank’s AML Compliance Officer who shall provide take the applicable necessary action under the Bank’s AML Program and provide, as soon as reasonably practicable, the Fund’s AML Compliance Officer Designated Contact with all available information related to the activity in question. A FundThe Bank’s AML Compliance Officer shall be responsible for determining will determine whether it is appropriate to file a Suspicious Activity Report suspicious activity report (“SAR”) on behalf of the Fund and for the completion of any such filing. If appropriate, the Bank’s AML Compliance Officer will then ensure a SAR is properly filed on behalf of the Bank. Each party will ensure it has appropriate section 314(b) certifications on file to permit such sharing of information.