Common use of Sanctions Program Clause in Contracts

Sanctions Program. The Depositor represents, covenants, and warrants that it has and any Agent engaged by it has adopted, implemented, and shall maintain and comply with a reasonable risk-based program to comply with all applicable economic, trade, and financial sanctions laws, resolutions, executive orders, and regulations enacted by the United States (including as administered and/or enforced by the Office of Foreign Assets Control), the United Kingdom, United Nations, European Union, and any applicable sanctions authority (collectively, “Sanctions Laws”). The Depositor represents, covenants, and warrants that it and any Agent shall maintain and comply with policies, procedures, and controls that are reasonably designed to ensure (i) compliance with Sanctions Laws and limit the risk of transactions that could be regarded as circumventing Sanctions Laws and (ii) that it, its affiliates, or its Agents and, to the extent required by law, its and their owners and controllers (a) are not in violation of any Sanctions Laws or on any list of prohibited individuals or entities enacted under Sanctions Laws (collectively, “Sanctions Lists”) and (b) are not located, organized, or doing business in a country or territory that is, or whose government is, the target of embargo or countrywide sanctions under any Sanctions Laws. The Depositor represents, covenants, and warrants that any Delivery to the Trust performed by the Depositor or its Agent shall not be directly or indirectly derived from, invested for the benefit of or related in any way to, persons, entities, or jurisdictions that are subject to any country embargoes, in violation of any Sanctions Laws or on any Sanctions Lists.