ANTI -MONEY LAUNDERING PROGRAM CERTIFICATION

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ANTI -MONEY LAUNDERING PROGRAM CERTIFICATION Powered By Docstoc
					Wachovia Corporation
Compliance Risk Management
NC0753
301 South Tryon Street
Charlotte, NC 28288




            ANTI-MONEY LAUNDERING PROGRAM CERTIFICATION
Wachovia Corporation1 and its subsidiaries (hereinafter collectively referred to
as "Wachovia") certify to having in place processes to establish, maintain and
review policies and procedures that are reasonably designed to achieve
compliance with applicable United States' anti-money laundering and anti-
terrorist financing (hereinafter collectively referred to as "AML") requirements.

Wachovia is resolved to conduct business and operations with high ethical
standards and in conformity with AML laws and regulations including, but not
limited to, the Bank Secrecy Act (BSA) as amended by the Uniting and
Strengthening America by Providing Appropriate Tools Required to Intercept
and Obstruct Terrorism (USA PATRIOT) Act, and the Office of Foreign Assets
Control (OFAC) regulations. To this end, Wachovia has adopted an AML
program that is comprised of the following essential elements:

      •   AML governance characterized by the designation of a BSA Officer,
          responsible for maintaining senior leadership commitment, establishing
          enterprise wide AML compliance processes, and setting and directing
          enterprise AML strategy.

      •   Policies and procedures that set corporate standards pertaining to the
          detection and appropriate reporting of money laundering and terrorist
          financing.

      •   Awareness, training, and communication to promote a risk culture that
          supports AML compliance.

      •   Audit and testing that provide independent evaluation of the AML
          program and validates and tests AML process and procedure
          effectiveness.




1
    Wachovia Corporation (a publicly traded company on the New York Stock Exchange under
    the WB symbol) is one of the largest providers of financial services to retail, brokerage, and
    corporate customers throughout the United States. Wachovia also provides global services
    through more than 30 international offices. Online banking and brokerage products and
    services are available through Wachovia.com.


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Wachovia’s AML program depends on the skill and commitment of its
corporate AML staff, business unit compliance managers, corporate partners
and front line employees who work to implement applicable procedures.
Business lines within Wachovia engage in processes designed to establish ,
maintain and review written procedures consistent with corporate AML
Policies, including procedures for large currency transaction reporting, OFAC,
customer identification verification, customer due diligence, account
monitoring, training, overall program compliance assessment and compliance
with section 312 of the USA PATRIOT Act. A central corporate unit manages
AML suspicious activity reporting and investigations pertaining to money
laundering or terrorist financing.

Additional information on Wachovia may be accessed via the Internet at
Wachovia.com. General information including, the members of management,
assets, locations of operation, financial centers, products, and services can be
located within Company Information.

Wachovia's global certification pursuant to sections 313 and 319(b) of the USA
PATRIOT Act can be obtained at http://www.wachovia.com/legal by using the
link to the USA PATRIOT Act Information. Any changes to this document or to
the global certification will be given by publication on the Wachovia.com
website. Financial institutions using this document should check the
Wachovia.com website periodically to receive updated information. Wachovia
does not undertake to otherwise give notice to any financial institution of any
changes to this document.

This certification is for your reliance only and may not be relied upon by any
third party. Wachovia undertakes no responsibility to advise you in the event
the information in this letter should change. Please contact Daniel D. Soto,
SVP, Director Anti-Money Laundering, and Bank Secrecy Act Officer, via email
at dan.soto@wachovia.com with any questions.




Daniel D. Soto, SVP
Director of Anti-Money Laundering and BSA Officer
Wachovia Corporation and all of its subsidiaries

Executed on this 1st day of January, 2009




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