Common use of Xxxxxxx Xxxxx’x Compliance with Anti-Money Laundering Rules and Regulations Clause in Contracts

Xxxxxxx Xxxxx’x Compliance with Anti-Money Laundering Rules and Regulations. Xxxxxxx Xxxxx hereby represents that it has complied and will comply with Section 326 of the USA Patriot Act and the implementing rules and regulations promulgated thereunder in connection with broker/dealers’ anti-money laundering obligations. Xxxxxxx Xxxxx hereby represents that it has adopted and implemented, and will maintain a written anti-money laundering compliance program (“AML Program”) including, without limitation, anti-money laundering policies and procedures relating to customer identification as required by the USA Patriot Act and the implementing rules and regulations promulgated thereunder. In accordance with these applicable laws and regulations and its AML Program, Xxxxxxx Xxxxx agrees to verify the identity of its new customers; to maintain customer records; to check the names of new customers against government watch lists, including the Office of Foreign Asset Control’s (OFAC) list of Specially Designated Nationals and Blocked Persons. Additionally, Xxxxxxx Xxxxx will monitor account activity to identify patterns of unusual size or volume, geographic factors and any other “red flags” described in the USA Patriot Act as potential signals of money laundering or terrorist financing. Xxxxxxx Xxxxx will submit to the Financial Crimes Enforcement Network any required suspicious activity reports about such activity and further will disclose such activity to applicable federal and state law enforcement when required by law. Xxxxxxx Xxxxx will certify annually to the Dealer Manager that Xxxxxxx Xxxxx (i) has implemented its anti-money laundering compliance program and (ii) will perform the specified requirements of its customer identification policies and procedures.

Xxxxxxx Xxxxx’x Compliance with Anti-Money Laundering Rules and Regulations. Xxxxxxx Xxxxx hereby represents that it has complied and will comply with Section 326 of the USA Patriot Act and the implementing rules and regulations promulgated thereunder in connection with broker/dealers’ ' anti-money laundering obligations. Xxxxxxx Xxxxx hereby represents that it has adopted and implemented, and will maintain a written anti-money laundering compliance program (“"AML Program”") including, without limitation, anti-money laundering policies and procedures relating to customer identification as required by the USA Patriot Act and the implementing rules and regulations promulgated thereunder. In accordance with these applicable laws and regulations and its AML Program, Xxxxxxx Xxxxx agrees to verify the identity of its new customers; to maintain customer records; to check the names of new customers against government watch lists, including the Office of Foreign Asset Control’s 's (OFAC) list of Specially Designated Nationals and Blocked Persons. Additionally, Xxxxxxx Xxxxx will monitor account activity to identify patterns of unusual size or volume, geographic factors and any other “"red flags” " described in the USA Patriot Act as potential signals of money laundering or terrorist financing. Xxxxxxx Xxxxx will submit to the Financial Crimes Enforcement Network any required suspicious activity reports about such activity and further will disclose such activity to applicable federal and state law enforcement when required by law. Xxxxxxx Xxxxx will certify annually to the Dealer Manager that Xxxxxxx Xxxxx (i) has implemented its anti-money laundering compliance program and (ii) will perform the specified requirements of its customer identification policies and procedures.