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Anti-Money Laundering (AML) Forms and Information

The Anti-Money Laundering and Counter-Terrorism Financing legislation requires us to obtain certain details of the identity of investors and to verify that information with supporting documents before being able to process an application.

 

Anti-Money Laundering Forms

Vasco Fund Services use the standard customer identification forms published by the Financial Services Council (FSC). Vasco Fund Services will use updated customer identification forms for new account applications from 1 July 2014. The updated customer identification forms incorporate requirements of the Foreign Account Tax Compliance Act (US) and any similar laws designed to implement those laws in Australia (FACTA).

These forms should be used for all new account applications from 1 July 2014 when collections of FACTA information becomes mandatory.

Please complete the form below that relates to the type of investor you are and send us certified copies of the supporting documentation referred to in the form. Note that some investors (for example, some trustees) may need to complete more than one form. If you're unsure which form you should complete or have any questions, please contact us.

 

AML Forms

Individuals

Australian Companies

Foreign Companies

Australian Regulated Trusts and Trustees

Unregulated Trusts and Trustees

Partnerships & Partners

Associations

 

Definitions of Terms

Beneficial Interest Holder

A holder of any beneficial interest in a unit.

Close Associate of a Senior non-US Political Figure

A person who is widely and publicly known internationally to maintain an unusually close relationship with the Senior non-US Political Figure, and includes a person who is in a position to conduct substantial domestic and international financial transactions on behalf of the Senior non-US Political Figure.

FATF

Financial Action Task Force on Money Laundering.

FATF Country

A country that is a member of FATF (this includes Australia).

Government Entity

Any government or any state, department or other political subdivision thereof, or any governmental body, agency, authority or instrumentality in any jurisdiction exercising executive, legislative, regulatory or administrative functions of or pertaining to, government.

Immediate Family of Senior non-US Political Figure

Typically includes the Senior non-US Political Figure's parents, siblings, spouse, children and in-laws.

Jurisdiction that has been designated by the Secretary of the Treasury under Section 311 or 312 of the USA PATRIOT Act as warranting special measures due to money laundering concerns.

For a current list see http://www.fincen.gov/reg_section311.html

Non-Cooperative Jurisdiction

Any non-US country or territory that has been designated as non-cooperative with international anti-money laudering principles or procedures by an intergovernmental group or organisation, such as FATF, of which the US is a member and with which designnation the US representative to the group or organisation continues to concur.

Non-US Bank

An organisation that (i) is organised under the laws of a country outside the US; (ii) engages in the business of banking; (iii) is recognised as a bank by the bank supervisory or monetary authority of the country of its organisation or principal banking operations; (iv) receives deposits to a substantial extent in the regular course of its business; and (v) has the power to accept demand deposit, but does not include the US branches or agencies of a non-US Bank.

Non-US Shell Bank

A non-US Bank without a Physical Presence in any country, but does not include a Regulated Affiliate (being a non-US Shell Bank that (a) is an affiliate of a depository institution, credit union, or non-US Bank that maintains a Physical Presence in the US or a non-US country, as applicable; and (b) is subject to supervision by a banking authority in the country regulating such affiliated depository institution, credit union, or non-US Bank.)

Physical Presence

A place of business that is maintained by a non-US Bank and is located at a fixed address, other than solely a post office box or an electronic address, in a country in which the non-US Bank is authorised to conduct banking activities, at which loctaionthe non-US Bank: (a) employs one or more individuals on a full-time basis; (b) maintains operating records related to its banking activities; and (c) is subject to inspection by the banking authority that licensed the non-US Bank to conduct banking activities.

Publicly Traded Company

An entity whose securities are listed on a recognised securities exchange or quoted on an automated quotation systems in the US or country other than a non-Cooperative Jurisdiction, or a Wholly-owned subsidiary of such an entity.

Related Person

With respect to any entity, any interest holder, director, senior officer, trustee, beneficiary or grantor of such entity; provided that in the case of an entity that is Publicly Traded Company or a US Qualified Plan, the term 'Related Person' shall exclude any interest holder holding less than five percent of any class of securities of such Publicly Traded Company and beneficiaries of such US Qualified Plan.

Senior non-US Political Figure

A senior official in the executive, legislative, administrative, military or judicial branches of a non-US Political Party, or a senior executive of a non-US Government-owned Corporation; and any corporation, business or other entity that has been formed by, or the benefit of, a Senior non-US Political Figure.

US Qualified Plan

A tax qualified pension or retirement plan in which at least 100 employess participate that is maintained by an employer that is organised in the US or is a IS government entity.

USA PATRIOT Act

The Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism of 2001 (Pub. L. No. 107-56) - see http://www.fincen.gov/pa_main.html

US Specially Designated Nationals List

A list maintained by the US Office of Foreign Assets Control - see www.treas.gov/offices/enforcement/ofac