BlackRock’s approach to compliance with the legislation

BlackRock’s approach to complying with the AML legislation is outlined below and differs depending on whether or not the investor applies to invest in a fund through a financial adviser*.

BlackRock requires an investor that directly applies to invest in the fund (that is, not through a financial adviser) to complete the Investor Identification Form which is incorporated within the application form for each fund and submit this together with the application form.

BlackRock requires an investor that directly applies to invest in the fund (that is, not through a financial adviser) to complete the Investor Identification Form. The Investor Identification Form can be downloaded at here.

The AML legislation allows for a product issuer (for example, BlackRock) to rely on the customer identification conducted by an intermediary (such as a financial adviser).

We will be relying on the customer identification / verification conducted by a financial adviser, and have amended the “Financial Adviser” section of the application form to include an “AML Investor Identification Certification”. This requires financial advisers to confirm that they have verified the identity of the investor and agree that BlackRock may access any document that has been used by the financial adviser to verify an investor’s identity.

Unless requested, we do not require original documents or certified copies used by the financial adviser to verify the identity of an investor. Where document(s) verifying the investor’s identity are provided to us by a financial adviser, BlackRock will still (as permitted under the AML legislation) rely on the financial adviser to verify the identity of the investor.

We recognise that some financial advisers will become compliant with the know your customer identification requirements of the AML legislation at different times prior to 12 March 2009 [the end of the ‘assisted compliance’ period]. If the identity of an investor has not been verified by the financial adviser, he or she is required to advise us. The application form has been amended to provide an option for this notification to occur.

In this instance, the financial adviser/investor will be required to complete and submit the Investor Identification Form together with the completed application form to enable us to verify the identity of the investor and accept the investor’s application to invest in the fund.

We may from time to time request identification/verification documentation from an investor or financial adviser to verify the investor’s identity.

A listing of the acceptable identification documents that we may require to enable us to verify a customer’s identity is provided in the Documents to verify an investor’s identity document.

Where documentation provided is not in English, an English translation must be provided by an accredited translator.

We are required to verify the identity of legal representatives and agents appointed to act on behalf of an investor. We cannot proceed to act on the instructions of a nominated legal representative until such time as we verify the identity of that representative.

Appointed legal representatives include, but are not limited to, executors of estates, attorneys [appointed under power of attorney] and nominated representatives.