ANTI-MONEY LAUNDERING SERVICES AMENDMENT
Exhibit 23(n)(vi)
ANTI-MONEY LAUNDERING SERVICES AMENDMENT
October 31, 2006
Dear Sir or Madam:
SELECT SECTOR SPDR TRUST (the “Fund”) and STATE STREET BANK & TRUST COMPANY (the “Transfer Agent”)
are parties to an agreement dated as of December 1, 1998 (the “Agreement”) under which the Transfer
Agent performs certain transfer agency and/or recordkeeping services for the Fund. In connection
with the enactment of the Uniting and Strengthening America by Providing Appropriate Tools Required
to Intercept and Obstruct Terrorism Act of 2001 (“USA PATRIOT Act”) and the regulations promulgated
thereunder (collectively, the “Patriot Act”), the Fund has requested and the Transfer Agent has
agreed to amend the Agreement as of the date hereof in the manner set forth below:
WHEREAS, Section 326 of the USA PATRIOT Act (the “Patriot Act”) and final rules adopted by the
Department of the Treasury’s Financial Crimes Enforcement Network (the “Rules”) require the Fund to
develop and implement an anti-money laundering program, which among other things, is designed to
verify the identity of any person opening an account, determine whether such person appears on
lists of known or suspected terrorists or terrorist organizations and identify and report unusual
and suspicious account activity to regulators;
WHEREAS, the Patriot Act authorizes a mutual fund to delegate to a service provider,
including its transfer agent, the implementation and operation of certain aspects of the Fund’s
anti-money laundering program;
WHEREAS, in order to assist its transfer agent clients with their customer identification
compliance responsibilities under the Patriot Act and the Rules, the Transfer Agent has provided to
the Fund for its consideration and approval written procedures describing various tools designed to
assist in the (i) verification of the identity of persons opening accounts with the Fund and
determination whether such persons appear on any list of known or suspected terrorists or terrorist
organizations, and (ii) identification and reporting of unusual and suspicious activity in
connection with accounts opened with the Fund and the Fund has, after review, selected various
procedures to comply with its customer identification and suspicious activity monitoring program
and its obligations under the Patriot Act and the Rules (the “Program”);
WHEREAS, in connection with the verification of customers’ identities and identification and
reporting of unusual and suspicious activity (“Monitoring Activities”), the Transfer Agent may
encounter shareholder activity that would require it to file a Suspicious Activity Report (“SAR”)
with the Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”); and
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WHEREAS, FinCEN recently adopted a rule (the “Rule”) under the Bank Secrecy Act (the “Act”)
requiring mutual funds to report suspicious transactions, effective for any transactions occurring
after October 31, 2006 (“Effective Date”);
WHEREAS, the Fund desires to delegate to the Transfer Agent the day-to-day responsibility for
filing SARs on its behalf based on suspicious transactions observed during the course of Monitoring
Activities, on or after the Effective Date; and
WHEREAS, the Fund recognizes the importance of complying with the Patriot Act and desires to
implement its procedures as part of its overall anti-money laundering program and, subject to the
terms of the Rules, delegate to the Transfer Agent the day-to-day operation of certain of its
procedures on behalf of the Fund;
NOW THEREFORE, in consideration of the foregoing and the mutual covenants and agreements
hereinafter contained, the parties hereby agree to amend the Agreement, pursuant to the terms
thereof, as follows:
1. Delegation; Duties.
1.1 Subject to the terms and conditions set forth in the Agreement, the Fund hereby instructs
and directs the Transfer Agent to implement the procedures on its behalf as set forth on Exhibit A,
which is attached to and made a part of this Agreement (the “Procedures”). Exhibit A may be
amended, from time to time, by the Transfer Agent in writing to the Fund with at least 30 days
prior notice of such effective change.
1.2 The Transfer Agent agrees to perform such Procedures, with respect to the ownership of
shares in the Portfolio(s) set forth in Exhibit B (each a Portfolio) for which the Transfer Agent
maintains the applicable participant information, subject to and in accordance with the terms and
conditions of the Agreement. Exhibit B, which is attached to and made a part of this Agreement,
may be amended from time to time by mutual agreement of the parties upon the execution by both
parties of a revised Exhibit B.
1.3 The Fund acknowledges that it has had an opportunity to review, consider and comment upon
and select the Procedures and the Fund has determined that they, as part of the Fund’s overall
anti-money laundering Program, are reasonably designed to prevent the Fund from being used for
money laundering or the financing of terrorist activities and to achieve compliance with the
applicable provisions of the Patriot Act, Bank Secrecy Act and their implementing regulations
thereunder, which compliance the Fund acknowledges to be its responsibility. Notwithstanding
anything to the contrary contained in this Agreement, in no event shall the Transfer Agent be
obligated to file with any regulator, on behalf of the Fund, any requisite forms or other
information in connection with the Program. Any filing by the Transfer Agent shall be in its own
name and on its own behalf. The Fund shall be responsible for complying with any and all requisite
regulatory filings which arise as a result of the Procedures or Program generally.
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1.4 Except as otherwise expressly stated in this Amendment, the Transfer Agent makes no
representation or warranty, either express, implied or statutory, concerning the Procedures herein.
The Fund expressly confirms that it has not relied upon any representation by the Transfer Agent
as a basis for entering into this Amendment. The provisions of this §1.4 shall survive the
termination of this Amendment.
2. Consent to Examination. In connection with the performance by the Transfer Agent of the
Procedures, the Transfer Agent understands and acknowledges that the Fund remains responsible for
assuring compliance with the Patriot Act and that the records the Transfer Agent maintains for the
Fund relating to the Fund’s Program may be subject, from time to time, to examination and/or
inspection by federal regulators in order that the regulators may evaluate such compliance. The
Fund hereby directs that the Transfer Agent shall (1) permit federal regulators access to such
information and records maintained by the Transfer Agent and relating to the Transfer Agent’s
implementation of the Procedures on behalf of the Fund as they may request, and (2) permit such
federal regulators to inspect the Transfer Agent’s implementation of the Procedures on behalf of
the Fund. The Transfer Agent hereby consents to such examination and/or inspection and agrees to
cooperate with such federal examiners in connection with their review. For purposes of such
examination and/or inspection, the Transfer Agent will use its best efforts to make available,
during normal business hours, all required records and information for review by such examiners.
3. Limitation on Delegation.
3.1 The Fund acknowledges and agrees that in accepting the delegation hereunder, the Transfer
Agent is agreeing to perform only those aspects of the Fund’s Program that have been expressly
delegated as part of the Procedures and is not undertaking and shall not be responsible for any
other aspect of the Fund’s Program or for the overall compliance by the Fund with the Patriot Act.
Additionally, the parties acknowledge and agree that the Transfer Agent shall only be responsible
for performing the Procedures with respect to the ownership of shares in the Fund for which the
Transfer Agent maintains the applicable participant information.
3.2 The Fund also acknowledges and agrees that the Transfer Agent’s provision of the
Procedures hereunder is dependent upon the receipt by the Transfer Agent of certain services from
third parties. In the event services from any such third party becomes unavailable, the Transfer
Agent shall use reasonable efforts to obtain equivalent services from an alternative provider or
may, in its discretion, discontinue the delegated duties upon such prior notice to the Fund as may
be reasonably practicable. Notwithstanding anything to the contrary contained herein, the Transfer
Agent will have no liability for the performance or nonperformance of any such third party except
to the extent the Transfer Agent failed to exercise the same care in its selection of such third
party as the Transfer Agent exercises in the conduct of its own operations.
4. Reports. The Transfer Agent agrees to provide to the Fund (i) any reports received by
the Transfer Agent from any government agency pertaining to the Transfer Agent’s anti-money
laundering monitoring on behalf of the Fund as provided in this Amendment, (ii) any action taken in
response to anti-money laundering violations as described in (i), and (iii) an annual report of its
verification activities on behalf of the Fund. The Transfer Agent shall provide such
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other reports on the verification activities conducted at the direction of the Fund as may be
agreed to from time to time by the Transfer Agent and the Fund.
5. Fees & Expenses.
5.1 In consideration of the performance of the foregoing duties, the Fund agrees on behalf of
each of the Portfolios to pay the Transfer Agent a fee for each participant account as set out in
the Fee Schedule which is attached to, and made a part of, this Agreement. Such fees and
out—of-pocket expenses and advances identified in §5.2 below may be changed from time to time
subject to mutual written agreement between the Fund and the Transfer Agent.
5.2 In addition to such fees paid under §5.1 above, the Fund agrees on behalf of each of the
Portfolios to reimburse the Transfer Agent for the reasonable administrative expenses that may be
associated with such additional duties including, but not limited to, confirmation production,
postage, forms, telephone, microfilm, microfiche, records storage, or advances incurred by the
Transfer Agent for the items set forth in the fee schedule attached hereto. The terms of the
Agreement shall apply with respect to the payment of such expenses in the same manner and to the
same extent as any other expenses incurred under the Agreement.
6. Reliance on Information and Authenticity. The Fund hereby acknowledges and understands
that the Transfer Agent’s ability to perform the Procedures under the terms and conditions set
forth in this Amendment is contingent upon the Fund’s ongoing cooperation with the Transfer Agent.
The Fund shall use all reasonable efforts in good faith to cooperate with the Transfer Agent taking
all action in a timely manner which the Transfer Agent, in its reasonable opinion, deems necessary
to enable or assist the Transfer Agent in performing any of the Procedures under this Agreement,
including but not limited to providing, or causing to be provided, to the Transfer Agent any
information or documents which the Transfer Agent deems reasonable or appropriate to provide the
duties hereunder. The Transfer Agent shall, when performing hereunder, be entitled to rely upon
(i) the accuracy of information, data and authorizations received from the Fund or any participant,
and (ii) the authenticity of any representation purporting to be from, or signature purporting to
be of, the Fund or a participant. In no event shall the Transfer Agent be liable in any way for
any losses, penalties, expenses or other harm or injury which may arise in connection with the
Transfer Agent’s delay in establishing, or refusal to establish, a participant account as a result
of the Transfer Agent’s failure to receive in a timely manner an application to open such account
which, in the Transfer Agent’s sole discretion, it deems complete.
7. Miscellaneous.
7.1 Except as set forth herein, the terms and provisions of the Agreement shall remain
unchanged and continue to apply with full force and effect. Except as otherwise defined herein,
all capitalized terms used in this Amendment shall have the same meaning as set forth in the
Agreement.
7.2 The parties to this Amendment understand and acknowledge that the Transfer Agent shall act
on behalf of and as agent for the Fund with respect to the Procedures. In no
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event shall the Transfer Agent be liable for its failure to perform under the terms of this
Amendment or any Exhibit, except where the Transfer Agent has acted with negligence or willful
misconduct. This Amendment shall not be deemed to constitute the Fund and the Transfer Agent as
partners or joint ventures.
7.3 The Fund shall indemnify and hold harmless the Transfer Agent from and against any and all
losses, penalties, expenses or other harm or injury which the Transfer Agent may incur or suffer or
which may be asserted by any person or entity, including reasonable attorneys’ fees and court
costs, arising out of (i) any failure by the Fund to observe and perform properly each and every
covenant of this Amendment or any other wrongdoing of the Fund, or (ii) any action taken or omitted
to be taken by the Transfer Agent in reasonable reliance upon information provided to the Transfer
Agent by the Fund; provided, however, that the Fund shall not be required to indemnify and hold
harmless the Transfer Agent from any losses which are caused by the Transfer Agent’s negligence.
The foregoing provisions of this §7.3 shall survive the termination of this Amendment.
7.4 In the event that the Transfer Agent, in its sole judgment, believes that its performance
of any duty set forth herein may create a risk of financial, reputation or other loss for it, the
Transfer Agent may, upon notice to the Fund, suspend its performance of the Procedures; provided,
however, that if the Fund takes such action as may be requested by the Transfer Agent to eliminate
such risk, the Transfer Agent shall not suspend the Procedures, or, if the Procedures have been
suspended, shall reinstate its provision of the Procedures.
7.5 The Transfer Agent represents that it is subject to regulation requiring it to
implement an anti-money laundering program, and further represents that it is regulated by a
“federal functional regulator” within the meaning of the Bank Secrecy Act, the Patriot Act, and the
applicable rules and regulations in connection therewith.
7.6 The Transfer Agent agrees to certify annually to the fund that it has implemented an
AML program and that it or its agent(s) will perform the specific requirements of the Customer
Identification and Suspicious Activity Procedures of the Fund, i.e., the procedures required by
Section 326 of the Patriot Act.
7.7 Each party represents to the other that the execution and delivery of this Amendment has
been duly authorized.
IN WITNESS WHEREOF, each of the parties has caused this Amendment to be executed in
its name and behalf by its duly authorized representative as of the date first above written.
| STATE STREET BANK AND TRUST COMPANY | ||||||
| By: | ||||||
| Name: | ||||||
| Title: | ||||||
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Exhibit A
Procedures
Procedures
The Transfer Agent agrees to perform the duties set forth below, with respect to the ownership of
shares in the Portfolio(s) set forth in Exhibit B for which the Transfer Agent maintains the
applicable account participant information, subject to and in accordance with the terms and
conditions of this Amendment. Notwithstanding anything to the contrary contained herein, in no
event shall State Street be obligated to verify the identity of any person who is not a United
States citizen or any entity (such as a corporation, partnership or trust), that is not established
or organized under the laws of a State or the United States. State Street shall scan such name
into its database to compare it against certain lists as described below.
I. Requests for New Account
Upon receipt from the Fund of an application to establish an account in the name of one of its
participants, the Transfer Agent shall review it for completeness. The Transfer Agent shall deem
the application complete as to the participant or any authorized signers or beneficiaries on the
account if with respect to such entity (i) the application includes such entity’s name, U.S.
resident street address, social security number and date of birth or (ii) the Fund (a) certifies to
the Transfer Agent as to the successful verification of the identity of such entity and the manner
in which the Fund verified such identity, and (b) provides the detailed information so verified
(i.e. passport number, drivers license number, birth certificate, etc.) which, in the Transfer’s
Agent’s opinion, fulfills applicable regulatory requirements.
If the application is incomplete as to the participant, the Transfer Agent will not open the
account and will notify the Fund and request additional information from the Fund. If the Fund
fails to provide the necessary participant information to complete the application within two
business days of the Transfer Agent’s request, the Transfer Agent shall promptly return the
application as incomplete and return any funds earmarked for deposit in such account to the
participant, unless upon receipt of the Transfer Agent’s request, the Fund requests additional time
to provide the missing information, in which case such application and funds will be returned to
the participant if the missing information is not provided within five (5) business days of the
Transfer Agent’s request. If the Transfer Agent determines, in its sole discretion, that the
participant information has been completed within a timely manner, the Transfer Agent shall
establish the account; provided, however, that such account shall be restricted
from any and all redemption transactions unless and until such restriction is lifted by the
Transfer Agent in accordance with the terms below.
If the participant information is complete but the application is incomplete as to any authorized
signer and/or beneficiary, the Transfer Agent will open the account and restrict such account from
any redemption transactions with respect to such entity unless and until such restriction is lifted
by the Transfer Agent in accordance with the terms below (see part III).
The Transfer Agent may file a Suspicious Activity Report or other appropriate report on its own
behalf with applicable regulator(s) if in attempting to collect any requisite information it deems
such action necessary or appropriate.
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The trade date for the purchase of shares on a newly established account shall be the date on which
the Transfer Agent deems the application complete as to participant information.
II. Screening Against the Blocked Persons and Other Restricted Lists
Newly Established Accounts
Once the application is deemed complete by the Transfer Agent and the account is established, the
Transfer Agent will scan the application into a database, inputting the name and address of the
participant and any authorized signer(s) and beneficiar(ies) on the account and shall compare it
against the published lists enumerated in Exhibit C, and such other lists as the Transfer Agent may
utilize, in an effort to determine whether or not such entity is named on any of the said lists (if
so, a so-called “Positive Match”).
Such scanning will result in a report of potential matches (the “Exception Report”), which may or
may not include a Positive Match. If, upon review of the Exception Report and any information
available to it, the Transfer Agent determines in its sole discretion that any potential match is
not a valid Positive Match, then such match will be deemed a False Match and the Transfer Agent
shall so document to the file without reporting it to the Fund. If the Transfer Agent believes a
potential match is a Positive Match or requires additional information to make a determination,
then such match will be reported to the Fund. If additional information is provided by the Fund,
the Transfer Agent will make any necessary corrections and will re-evaluate such “match” by
re-scanning the updated information. If the Transfer Agent determines, in its sole discretion,
that a Positive Match exists or that it is unable to determine with reasonable certainty that no
Positive Match exists, the Transfer Agent will notify the Fund and provide supporting
documentation. It also will 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 account.
If the Transfer Agent determines, in its sole discretion, that no Positive Match exists on items
reported, the Transfer Agent will notify the Fund and document its review. If the Fund, in its
sole discretion, believes that a Positive Match does exist, the Transfer Agent will take
instructions from the Fund, subject to any regulatory limitations, and will document its files.
Existing Accounts
Each month, or as otherwise agreed to by the parties, the Transfer Agent shall scan the
participant’s name and that of each authorized signer and beneficiary on existing accounts in an
effort to identify whether or not a Positive Match exists, in which case the Transfer Agent and
Fund shall act in accordance with the applicable terms above.
The Transfer Agent will retain records of scanning function and results, in accordance with
applicable Bank Secrecy Act regulation(s).
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III. Identity Verification
Upon receipt of a complete application, as described in Section I above, to establish an account or
add an authorized signer or beneficiary, the Transfer Agent will attempt to verify the identity of
the participant and its authorized signers and/or beneficiaries, as applicable. The extent and
nature of the information needed by the Transfer Agent to perform such verification shall depend
upon the nature of the accountholder, authorized signer or beneficiary (e.g. corporation,
individual, trust, non-U.S. resident) but shall at a minimum include, without limitation, the
entity’s name, U.S. street address, social security number and, if applicable, date of birth. The
Transfer Agent shall deem the identity verified, as to the participant or any authorized signers or
beneficiaries on the account, if (i) such entity’s name, U.S. resident street address, social
security number and date of birth matches information in the database utilized by the Transfer
Agent or (ii) the Fund, to the Transfer Agent’s reasonable satisfaction, (a) certifies to the
successful verification by the Fund of the identity of such entity and the manner in which the Fund
verified such identity, and (b) provides copies of the detailed information verified (i.e. passport
number, drivers license number, birth certificate, etc.) which, in the Transfer’s Agent’s opinion,
fulfills applicable regulatory requirements. Examples of acceptable documentary evidence, as
agreed upon by the parties, include driver’s license, military driver’s license or other military
identification card, alien registration card, birth certificate, identification card issued by a
state within the last 6 months, certified copy of a court order with full name and date of birth,
and passport.
The Transfer Agent also shall attempt to so verify the identity of any authorized signer or
beneficiary which the Fund and/or participant requests to be added to any existing account
established after October 1, 2003.
In cases where the Fund has not certified to the entity’s identity as described above and the
Transfer Agent is unable to verify such information, the Transfer Agent shall so notify the Fund,
furnish supporting documentation to it and request that additional evidence or such certification
from the Fund.
In cases where the participant’s identity cannot be verified by the Transfer Agent and the Fund has
failed to provide a certification with respect to the participant’s identity to the Transfer
Agent’s reasonable satisfaction, the Transfer Agent, in its sole discretion or upon the Fund’s
request, may close the account. If it is an authorized signer or beneficiary’s identity that
cannot be verified to the Transfer Agent’s reasonable satisfaction, the Transfer Agent, in its sole
discretion or at the Fund’s request, may close the account or refuse to add such entity(ies) to the
account. In either case, 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 account.
The Transfer Agent shall redeem any shares in a closed account with the opening net asset value as
of the date on which such account was closed, with the proceeds forwarded to the participant when
available.
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Lifting of Restrictions on Redemptions.
The restrictions against redemption transactions with respect to an account or any authorized
signer or beneficiary on such account shall be removed only when the Transfer Agent determines that
(i) no Positive Match exists with respect to the participant, authorized signer or beneficiary, as
the case may be, and (ii) such entity’s identity has been verified by the Transfer Agent as
described above.
IV. 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 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, if it deems appropriate, will report such activity to
the Risk and Compliance Group. The Risk and Compliance Group will review such activity further and
prepare a draft SAR on Form SAR-SF and send a copy to the Fund’s AML Officer for review. The
Fund’s AML Officer shall review the SAR and provide comments, if any, to the Risk and Compliance
Group. The Risk and Compliance Group will file the appropriate report(s) on own behalf of the
Transfer Agent and the Fund (“joint filing”) 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 account. The Risk and Compliance Group shall provide to the Fund a copy of each SAR
filed with supporting documentation which the Risk and Compliance Group will maintain for five (5)
years.
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With respect to any newly established account, the Transfer Agent will review the account for
thirty (30) days following the initial deposit into such account for any and all redemptions that
occur and determine, in its sole discretion, whether or not any such redemptions are “suspicious”
in nature. If the Transfer Agent determines that any redemption is suspicious, it will promptly
notify the Fund, unless prohibited by applicable law, rule or regulation, 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
account.
The Fund acknowledges that the Transfer Agent does not accept cash equivalents (bank drafts, bank
notes, etc.) in connection with any participant accounts.
The Transfer Agent will notify the Fund of any change in payment instructions which in the sole
discretion of the Transfer Agent is deemed to be “suspicious” in nature and await instruction from
the Fund as to whether or not such change should be implemented by the Transfer Agent.
The Transfer Agent will review any changes to an account’s statement address that occur within 30
days of the account opening and notify the Fund of any such changes that it deems to be
“suspicious” in nature, unless prohibited by applicable law, rule or regulation. Upon such notice
or upon instruction from the Fund, 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 account.
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Exhibit B — Fund List
The Materials Select Sector SPDR Fund |
XLB | |||
The Consumer Discretionary Select Sector SPDR Fund |
XLV | |||
The Consumer Staples Select Sector SPDR Fund |
XLP | |||
The Healthcare Select Sector SPDR Fund |
XLY | |||
The Energy Select Sector SPDR Fund |
XLE | |||
The Financial Select Sector SPDR Fund |
XLF | |||
The Industrial Select Sector SPDR Fund |
XLI | |||
The Technology Select Sector SPDR Fund |
XLK | |||
The Utilities Select Sector SPDR Fund |
XLU | |||
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Exhibit C
OFAC SDN list
OFAC Blocked Countries
Bank of England
Canadian Consolidated List (OSFI)
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