The Originator (directly or through an Affiliate) has implemented and maintains in effect policies and procedures designed to provide for compliance by the Originator, its Affiliates and their respective directors, officers, employees and agents with Anti-Corruption Laws and applicable Sanctions, and the Originator, its Affiliates and their respective directors, officers and employees and, to the Acknowledge of the Originator, their respective authorized agents, are in compliance with Anti-Corruption Laws and applicable Sanctions. None of (i) the Originator, its Affiliates or, to the Actual Knowledge of the Originator, any of their respective directors, officers or employees, or (ii) to the Actual Knowledge of the Originator, any agent of the Originator or its Affiliates that will act in any capacity in connection with or benefit from the transactions contemplated by the Transaction Documents, is a Sanctioned Person. The direct or indirect use of any proceeds of any sale of Receivables hereunder will not result in a violation by any Company Party of any Anti-Corruption Laws or applicable Sanctions.