Laundering Services Clause Samples

Laundering Services. MSSCI agrees to comply with all aspects of anti-money laundering laws and regulations to the extent applicable to MSSCI under applicable laws in connection with services hereunder, including any such applicable aspects the Bank Secrecy Act, as amended by the USA PATRIOT Act, and implementing regulations of the Bank Secrecy Act and applicable guidance issued by the SEC and the guidance and rules of the applicable Exchanges, SROs and FINRA. The Fund is responsible for its compliance with anti-money laundering regulations and guidance applicable to it. MSSCI will assist the Fund in meeting its obligations by carrying out the services set forth below (the “Delegated Duties”). For purposes of the Delegated Duties, it will be assumed that the Fund is a financial institution subject to U.S. anti-money laundering laws (“AML Laws”). The Fund will adopt anti-money laundering operational guidelines (the “AML Program”) and MSSCI agrees to perform the Delegated Duties in accordance with the AML Program, provided the AML Program and any material amendments thereto be submitted to MSSCI for its review and consent. The following services are hereby delegated to MSSCI: MSSCI shall perform the AML Services for the Fund’s prospective shareholders and will determine whether the customer appears on the publicly available lists published by the U.S. government of terrorist organizations and blocked persons. MSSCI will monitor, identify and report suspicious activities that are required to be so identified and reported to the Fund’s AML Compliance Officer, consistent with the AML Program and as set forth on the attached schedule. MSSCI will place holds on transactions in shareholder accounts or freeze assets in shareholder accounts, in accordance with AML Program and create documentation to provide a basis for law enforcement authorities to trace illicit funds. MSSCI will maintain, in accordance with the AML Program, all records or other documentation related to shareholder accounts and transactions therein that are required by law and pursuant to the AML Program to be prepared and maintained by MSSCI for the requisite period. MSSCI will make all such records and documentation available for inspection by (i) the Fund’s AML Compliance Officer, (ii) any auditor of the Fund’s AML Program or related procedures, policies or controls that have been designated by the Fund in writing, or (iii) regulatory or law enforcement authorities, (vi) where appropriate, the Directors and Officers ...
View SourceView Similar (2)
Laundering Services. 1. The University shall provide laundering services to all Residents at no cost for white coats and scrubs at the University.
View Source
Laundering Services. 1. The University shall provide laundering services to all Residents at no cost for white coats scrubs at UC ▇▇▇▇▇.
View Source
Laundering Services. In each case consistent with and as required or permitted by the written anti-money laundering program (“AML Program”) of the Trust:
View Source
Laundering Services. Dear Sir/Madam: This letter constitutes our agreement with respect to compensation to be paid to PFPC Inc. (“PFPC”) under the terms of an Anti-Money Laundering Amendment dated on or about the date hereof (the “Amendment”) to the Transfer Agency and Services Agreement dated April 1st 1998 (the “Agreement”) between Forward Funds (the “Company”) and PFPC for anti-money laundering (“AML”) services provided to or on behalf of the Company. In consideration only of the AML services to be provided to the Company, the Company will pay PFPC an annual AML services fee to be calculated and paid monthly as set forth below. Such fees are in addition to, and in no way replace, other fees to which the parties hereto have agreed in connection with the Agreement or any amendment thereto.
View Source
Laundering Services. The Financial Crimes Enforcement Network (“FinCEN”) issues requests for information under Section 314(a) of the USA PATRIOT Act every two weeks. The Trust designates the Administrator to receive 314(a) requests from FinCEN on behalf of the Trust. Upon receiving a request from FinCEN, the Administrator, on behalf of the Trust, will forward the request to the Trust’s transfer agent, DST Systems, Inc., to scan shareholder records for matches with names on the request list as required under Section 314(a). The Administrator will communicate any matches to FinCEN within 2 weeks from the posting date of the 314(a) request. The Trust may register under Section 314(b) of the USA PATRIOT Act. If the Trust so registers, the Trust designates the Administrator to receive 314(b) requests from financial institutions on behalf of the Trust. Upon receiving a 314(b) request from a financial institution, the Administrator, on behalf of the Trust, will forward the request to the Trust’s transfer agent, DST Systems, Inc., to scan shareholder records for matches with names on the request list pursuant to Section 314(b). The Administrator will communicate any matches to the financial institution in accordance with Section 314(b). The Administrator will maintain, for a period of not less than five years, copies of all records and communications, including training materials, as are reasonably necessary, consistent with applicable law, to document the implementation and operation of these anti-money laundering services.
View Source

Related to Laundering Services

  • Anti-Money Laundering Compliance Programs Each Dealer’s acceptance of this Agreement constitutes a representation to the Managing Broker-Dealer that the Dealer has established and implemented an anti-money laundering (“AML”) compliance program (“AML Program”), in accordance with FINRA Rule 3310 and Section 352 of the Money Laundering Abatement Act, the Bank Secrecy Act, as amended, and Section 326 of the Patriot Act of 2001, which are reasonably expected to detect and cause reporting of suspicious transactions in connection with the sale of Shares. In addition, the Dealer represents that it has established and implemented a program (“OFAC Program”) for compliance with OFAC and will continue to maintain its OFAC Program during the term of this Agreement. Upon request by the Managing Broker-Dealer at any time, the Dealer hereby agrees to (i) furnish a copy of its AML Program and OFAC Program to the Managing Broker-Dealer for review and (ii) furnish a copy of the findings and any remedial actions taken in connection with the Dealer’s most recent independent testing of its AML Program and/or its OFAC Program. The parties acknowledge that for the purposes of the FINRA rules the Investors who purchase Shares through the Dealer are “Customers” of the Dealer and not the Managing Broker-Dealer. Nonetheless, to the extent that the Managing Broker-Dealer deems it prudent, the Dealer shall cooperate with the Managing Broker-Dealer’s auditing and monitoring of the Dealer’s AML Program and its OFAC Program by providing, upon request, information, records, data and exception reports, related to the Company’s investors introduced to, and serviced by, the Dealer (the “Customers”). Such documentation could include, among other things: (i) copies of Dealer’s AML Program and its OFAC Program; (ii) documents maintained pursuant to the Dealer’s AML Program and its OFAC Program related to the Customers; (iii) any suspicious activity reports filed related to the Customers; (iv) audits and any exception reports related to the Dealer’s AML activities; and (v) any other files maintained related to the Customers. In the event that such documents reflect, in the opinion of the Managing Broker-Dealer, a potential violation of the Managing Broker-Dealer’s obligations in respect of its AML or OFAC requirements, the Dealer will permit the Managing Broker-Dealer to further inspect relevant books and records related to the Customers (with respect to the Offering) and/or the Dealer’s compliance with AML or OFAC requirements. Notwithstanding the foregoing, the Dealer shall not be required to provide to the Managing Broker-Dealer any documentation that, in the Dealer’s reasonable judgment, would cause the Dealer to lose the benefit of attorney-client privilege or other privilege which it may be entitled to assert relating to the discoverability of documents in any civil or criminal proceedings. The Dealer hereby represents that it is currently in compliance with all AML rules and all OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act. The Dealer hereby agrees, upon request by the Managing Broker-Dealer to (i) provide an annual certification to the Managing Broker-Dealer that, as of the date of such certification (A) its AML Program and its OFAC Program are consistent with the AML Rules and OFAC requirements, (B) it has continued to implement its AML Program and its OFAC Program and (C) it is currently in compliance with all AML Rules and OFAC requirements, specifically including, but not limited to, the Customer Identification Program requirements under Section 326 of the USA PATRIOT Act and (ii) perform and carry out, on behalf of both the Managing Broker-Dealer and the Company, the Customer Identification Program requirements in accordance with Section 326 of the USA PATRIOT Act and applicable SEC and Treasury Department Rules thereunder.

  • Anti-Money Laundering Compliance A. Each of Distributor and Client acknowledges that it is a financial institution subject to the USA PATRIOT Act of 2001 and the Bank Secrecy Act (collectively, the “AML Acts”), which require, among other things, that financial institutions adopt compliance programs to guard against money laundering. Each represents and warrants to the other that it is in compliance with and will continue to comply with the AML Acts and applicable regulations in all relevant respects. B. The Distributor shall include specific contractual provisions regarding anti-money laundering compliance obligations in agreements entered into by the Distributor with any broker-dealer or other financial intermediary that is authorized to effect transactions in Shares of the Funds. C. Each of Distributor and Client agrees that it will take such further steps, and cooperate with the other as may be reasonably necessary, to facilitate compliance with the AML Acts, including but not limited to the provision of copies of its written procedures, policies and controls related thereto (“AML Operations”). Distributor undertakes that it will grant to the Client, the Client’s anti-money laundering compliance officer and appropriate regulatory agencies, reasonable access to copies of Distributor’s AML Operations, and related books and records to the extent they pertain to the Distributor’s services hereunder. It is expressly understood and agreed that the Client and the Client’s compliance officer shall have no access to any of Distributor’s AML Operations, books or records pertaining to other clients or services of Distributor.

  • Anti-Money Laundering Program The Trust acknowledges that it has had an opportunity to review, consider and comment upon the written procedures provided by USBFS describing various tools used by USBFS which are designed to promote the detection and reporting of potential money laundering activity by monitoring certain aspects of shareholder activity as well as written procedures for verifying a customer’s identity (collectively, the “Procedures”). Further, the Trust has determined that the Procedures, as part of the Trust’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 USA Patriot Act of 2002 and the implementing regulations thereunder. Based on this determination, the Trust hereby instructs and directs USBFS to implement the Procedures on the Trust’s behalf, as such may be amended or revised from time to time. It is contemplated that these Procedures will be amended from time to time by the parties as additional regulations are adopted and/or regulatory guidance is provided relating to the Trust’s anti-money laundering responsibilities. USBFS agrees to provide to the Trust: (a) Prompt written notification of any transaction or combination of transactions that USBFS believes, based on the Procedures, evidence money laundering activity in connection with the Trust or any shareholder of the Fund; (b) Prompt written notification of any customer(s) that USBFS reasonably believes, based upon the Procedures, to be engaged in money laundering activity, provided that the Trust agrees not to communicate this information to the customer; (c) Any reports received by USBFS from any government agency or applicable industry self-regulatory organization pertaining to USBFS’s anti-money laundering monitoring on behalf of the Trust; (d) Prompt written notification of any action taken in response to anti-money laundering violations as described in (a), (b) or (c); and (e) Certified annual and quarterly reports of its monitoring and customer identification activities on behalf of the Trust. The Trust hereby directs, and USBFS acknowledges, that USBFS shall (i) permit federal regulators access to such information and records maintained by USBFS and relating to USBFS’s implementation of the Procedures, on behalf of the Trust, as they may request, and (ii) permit such federal regulators to inspect USBFS’s implementation of the Procedures on behalf of the Trust.

  • Money Laundering The operations of the Company and its Subsidiaries are and have been conducted at all times in compliance with applicable financial record-keeping and reporting requirements of the Currency and Foreign Transactions Reporting Act of 1970, as amended, applicable money laundering statutes and applicable rules and regulations thereunder (collectively, the “Money Laundering Laws”), and no Action or Proceeding by or before any court or governmental agency, authority or body or any arbitrator involving the Company or any Subsidiary with respect to the Money Laundering Laws is pending or, to the knowledge of the Company or any Subsidiary, threatened.

  • Anti-Money Laundering and Client Screening With respect to the Trust’s or any Portfolio’s offering and sale of Creation Units at any time, and for all subsequent transfers of such interests, the Trust or its delegate shall, to the extent applicable, directly or indirectly and to the extent required by law: (i) conduct know your customer/client identity due diligence with respect to potential investors and transferees in the Shares and Creation Units and shall obtain and retain due diligence records for each investor and transferee; (ii) use its best efforts to ensure that each investor’s and any transferee’s funds used to purchase Creation Units or Shares shall not be derived from, nor the product of, any criminal activity; (iii) if requested, provide periodic written verifications that such investors/transferees have been checked against the United States Department of the Treasury Office of Foreign Assets Control database for any non-compliance or exceptions; and (iv) perform its obligations under this Section in accordance with all applicable anti-money laundering laws and regulations. In the event that the Transfer Agent has received advice from counsel that access to underlying due diligence records pertaining to the investors/transferees is necessary to ensure compliance by the Transfer Agent with relevant anti-money laundering (or other applicable) laws or regulations, the Trust shall, upon receipt of written request from the Transfer Agent, provide the Transfer Agent copies of such due diligence records.