Common use of Transfer Agent Duties and Responsibilities Clause in Contracts

Transfer Agent Duties and Responsibilities. In performing the services of the AML Program the Transfer Agent shall: a. perform the follows functions using reasonable commercial efforts - i. Maintain a Customer Identification Program (as defined in 31 CFR 1024.220) including maintaining records required under applicable regulations; ii. Monitor customer accounts for suspicious activity (as described in 31 CFR 1024.320); iii. Maintain an identity theft program which includes the monitoring and reporting of suspicious activity (as described in Regulation S-ID); iv. Maintain a training program for associates that cover these requirements; v. Screen customer records against OFAC databases to determine whether the customer is subject to OFAC sanctions program; vi. Screen account information against any Financial Crimes Enforcement Network (“FinCEN”) request under 31 CFR § 1010.520 delivered to ALPS by the Fund or by ALPS Distributors, Inc. (“ADI”), if ADI serves as the Fund’s distributor, and provide the Fund or ADI with the necessary information for it to respond to such FinCEN request within the required time frame; b. promptly notify the Trust of any transaction or combination of transactions that ALPS believes evidence money laundering or identity theft activities in connection with the Trust or any Fund shareholder.