MoneyGram 2009 Annual Report Download - page 399

(a) will comply with the Patriot Act and all applicable regulations and executive orders issued thereto and any other applicable AML Laws,
(b) will refrain from taking any action that would result in a violation by the Purchasers of the Patriot Act and all applicable regulations and executive
orders issued thereto or any other applicable AML Laws, and
(c) without limiting the generality of the foregoing, will:
(i) establish and adhere to a program to ensure the filing of all required reports under the AML Laws, and
(ii) establish and adhere to a program and all other requirements to perform due diligence as required by the Bank Secrecy Act,
in each case, except as could not reasonably be expected to have a Material Adverse Effect.
7.3. U.S. Economic Sanctions.
Holdco and its Subsidiaries:
(a) will comply with any U.S. Economic Sanction imposed by any rule, regulation or statute of the United States, including, without limitation, those
administered by OFAC and any other applicable laws imposing economic sanctions,
(b) will refrain from taking any action that would result in a violation by the Purchasers of U.S. Economic Sanctions, and
(c) without limiting the generality of the foregoing, will not approve, facilitate, or fund, directly or indirectly, any business activities with, or for the benefit
of, a government, national, resident or legal entity of any country with respect to which U.S. persons, as defined in U.S. Economic Sanctions, are prohibited
by U.S. Economic Sanctions from doing business, except to the extent otherwise permitted by the relevant Governmental Authority,
in each case, except as could not reasonably be expected to have a Material Adverse Effect.
7.4. FCPA and Anti-Bribery Limitations.
Holdco and its Subsidiaries:
(a) will comply with the U.S. Foreign Corrupt Practices Act and all other applicable anti-bribery or anti-corruption laws,
(b) will refrain from taking any action that would result in a violation by the Purchasers of the U.S. Foreign Corrupt Practices Act or any other applicable
anti-bribery or anti-corruption laws, and
(c) without limiting the generality of the foregoing, neither the Holdco nor any of its Subsidiaries, will offer, promise to pay, or authorize the payment of
any money, or will offer, give, promise to give, or authorize the giving of anything of value, to any officer, employee or any other person acting in an official
capacity for any Governmental Entity, to any Governmental Official or to any person under circumstances where such Affiliate knows or is aware of a high
probability that all or a portion of 37