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*.

* Financial Advisers include an Australian Financial Services (AFS) Licensee or a representative of an AFS Licensee

Investors that do not apply through a financial adviser

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


Investors that apply through/with an AML compliant financial adviser


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 the "Financial Adviser" section of the application forms for our funds includes an "AML Investor Identification Certification". This requires financial advisers to confirm that they have verified the identity of the investor and that they agree 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.


BlackRock's right to request information


We may from time to time request identification/verification documentation or other information from an investor or financial adviser to verify the investor's identity in compliance with the AML legislation.

A list of 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.

BlackRock reserves the right to seek out additional information/documents as it believes necessary in order to comply with the AML legislation.

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


Appointed representatives


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.

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