Customer Identification and Verification
In an effort to assist the government in the fight against funding terrorism and money-laundering activities, Federal law requires all financial institutions to obtain, verify and
record information that identifies each person who opens an account.
In addition to the information we must collect under the Funds’ Anti-Money Laundering
Program we will, at a minimum: verify, to the extent reasonable and practicable, the
identity of any customer seeking to open an account; maintain records of information
used to verify a customer's identity; and check that a customer does not appear on
government terrorist lists, such as the list on Treasury's Office of Foreign
(OFAC) Web Site. The types of information that we will collect before opening an
account are listed below.
Required Identifying Information
We will collect the following information for all accounts, if applicable, for any person,
entity or organization prior to opening a new account (or is being granted trading
authority over a new or existing account) and whose name is on the account or has
authority over the account: the name and mailing and residential (or principal place of
business) street address of the customer; the customer’s date of birth; and, for U.S.
persons, the customer’s Social Security number or taxpayer identification number. For
non-U.S. persons, the following information will be used to identify customers: a
taxpayer identification number, passport and country of issuance, an alien identification
card number or number and country of issuance of any other government-issued
document evidencing nationality or residence and bearing a photograph. Both entities
and natural persons who have applied for, but have not received a taxpayer identification
can open an account with the Fund(s) by providing an alternate form of identifying
information as set forth above.
Procedures Upon Failure to Verify/Customers Who Refuse to Provide Information
If a potential or existing customer either refuses to provide the information described
above, or appears to have intentionally provided misleading information, or the Fund
cannot form a reasonable belief that it knows the true identity of the customer based on
the information provided, the Fund(s) will not open a new account and, after considering
the risks involved, may consider closing any existing account. In either case, the Fund(s)
will report a customer’s refusal to provide such information or failure to verify the
identity of a customer to the AML Compliance Officer who must then determine whether
to file a Suspicious Activity Report (SAR) in accordance with applicable law.
To the extent reasonable and practicable, we will ensure that we have a reasonable belief
that we know the true identity of our customers by verifying and documenting the
accuracy of the information we receive about our customers. In verifying customer
identity, we will analyze any logical inconsistencies in the information we obtain.
Customer identity will be verified through documentary evidence, non-documentary
evidence, or both. We will use documents to verify customer identity when appropriate
documents are available and suitable to form a reasonable belief that we know the true
identity of the customer. We may also use such non-documentary means, after using
documentary evidence, if we are still uncertain about whether we know the true identity
of the customer.
Appropriate documentary information for verifying the identity of natural persons include
- An unexpired driver’s license, passport, or other government identification
showing nationality, residence, and photograph or, for non-U.S. persons, an
unexpired alien registration card or other government issued identification
showing nationality, residence and photograph.
The following documentary information will be used to verify the identity of businesses:
- A certificate of incorporation, a government-issued business license, any
partnership agreements, any corporate resolutions, or similar documents.
Verification of customer identity through the use of non-documentary evidence is
mandatory in the following situations: (1) when the customer is unable to present an
unexpired identification card with a photograph; (2) when the documents the customer
presents for identification verification are unfamiliar to the Fund(s); (3) when the
customer and Fund(s) do not have face-to-face contact; and (4) when there are other
circumstances that increase the risk that the Fund(s) will be unable to verify the true
identity of the customer through documentary means. Under these circumstances, we
will use the following non-documentary methods of verifying identity:
- Contact the customer after the account has been opened (although we will not rely
solely on customer contact as a means for verification);
- Obtain financial statements from the customer;
- Compare information obtained from the customer against public databases or
other in-house or custom databases;
- Compare information obtained from customer with information available from a
consumer reporting agency (such as a credit report);
- Check references with other financial institutions; and
- Any other non-documentary means deemed appropriate.
We will verify the information at the time new accounts are opened, if possible, but in
most situations no later than five business days after opening. We will document our
verification, including all identifying information provided by a customer, the methods
used and results of verification, and the resolution of any substantive discrepancy in the
identifying information. We will maintain those records for five years after the account
has been closed or the customer's trading authority over the account has ended.
Verification records will be retained for five years after the record is made.
Using Government Provided Lists of Terrorists and Other Criminals.
Before opening an account, and on an ongoing basis, we will check to ensure that a
customer does not appear on a list provided to us by the government, such as the
Treasury’s OFAC List. The OFAC Web Site can be viewed at www.treas.gov/ofac.
Because the OFAC Web Site is updated frequently, we will consult the list on a regular
In the event that we determine a customer, or someone with or for whom the customer is
transacting, is on the OFAC List or is from or engaging in transactions with a person or
entity located in an embargoed country or region, we will reject the transaction and/or
block the customer's assets and file a blocked assets and/or rejected transaction form with
OFAC. We will also call the OFAC Hotline at 1-800-540-6322.
Reliance on Other Financial Institutions
Due to the limited contact with potential and existing customers, the Fund(s) will rely on
a network of brokers/dealers with whom the Fund(s) have selling agreements with to
perform the initial customer identification and verification process. Outside
broker/dealers must complete the required field on the account application regarding
customer identification and retain such information in their records as required by law.
The Fund(s) will then create and maintain a record of the type of document, any
identification number contained in the document, place of issuance, and the issuance and
expiration date, if any, and include a description of the methods and results of any
measures undertaken to verify the identity of the customer from the information provided
on the account application.
Notice to Customers
In accordance with Federal law and prior to opening an account, the Fund(s) will provide
adequate notice to customers that it is requesting information from them to verify their
identities. The Fund(s) will use the following method to provide notice to customers: for
walk-in, and mail-in account applications, our customers will receive oral or written
notice of the method(s) used for verification regarding their identity. The notice will also
be included on the account application and posted on the Funds’ website.