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SERVICE

CARTA RESPONSIBILITIES

CLIENT RESPONSIBILITIES

Investor AML/KYC (Non-U.S. based Funds)

Carta will provide the following AML/KYC

Investor AML/KYC (Non-U.S. based Funds)

Carta will provide the AML/KYC services, including conduct Customer Due Diligence (“CDD”) for all investors and its connected parties, as follow:

Onboarding

Collecting and reviewing of CDD documents and relevant information as required

Identification and verification of the identities of the investor and its connected parties, such as -

Entity information;

Control person of entity;

Individual beneficial owner holding 10% or more interests, where applicable

Conduct screening on the investor and its connected parties and provide report to the Client on the screening results for the following watchlists:

Politically Exposed Person (PEP) list;

Sanctions list;

Enforcement list; and

Adverse media.

Perform risk rating assessment on the investor

Periodic monitoring

Review and request updated documents so as to maintain the documents/information up-to-date

Conduct screening

Perform risk rating assessment

Provide update to the Client on any change in the screening and risk rating

Perform recurring screening of applicable parties during the contract period

Client (either through Client’s GP or Client’s legal counsel) to provide Carta with all necessary KYC documents containing the relevant information required by Carta to perform the AML/KYC services on the investor and its connected parties. Investor’s KYC documents such as:

For Individuals:

Current passport;

Proof of address; and

Source of Funds and Source of Wealth Declaration and its supporting document

For entities:

Copy of formation documents;

Register of Directors and Controlling Persons;

Register of Shareholders;

Source of Funds and Source of Wealth Declaration;

Latest financial statement; and

Identification and verification of IDs of each director, controlling person and shareholder.

Note: List of KYC documents required subject to the types of investors.

, including conducting Customer Due Diligence (“CDD”) for all investors and  connected parties:

  1. Onboarding

    1. Collecting and reviewing of CDD documents and relevant information as required

    2. Identification and verification of the identities of the investor and connected parties, such as -

      • Entity information

      • Control person of entity

      • Individual beneficial owner holding 25% or more interests, where applicable

    3. Conduct screening on the investor and connected parties and report to the Client on the screening results for the following watchlists:

      • Politically Exposed Person (PEP) list;

      • Sanctions list;

      • Enforcement list; and

      • Adverse media

    4. Perform risk rating assessment on the investor

  2. Periodic monitoring

    1. Review and request updated documents to maintain  up-to-date documents/information 

    2. Conduct screening

    3. Perform risk rating assessment

    4. Provide updates to the Client on changes to the screening and risk rating

  3. Perform recurring  screening of applicable parties during the contract period 

Client (either through Client’s GP or Client’s legal counsel) to provide Carta with all necessary KYC documents containing the relevant information required by Carta to perform the AML/KYC services on the investor and its connected parties. Investor’s KYC documents include:

For Individuals:

  • Current passport;

  • Proof of address; and

  • Source of Funds and Source of Wealth Declaration and its supporting document

For entities:

  • Copy of formation documents;

  • Register of Directors and Controlling Persons;

  • Register of Shareholders;

  • Source of Funds and Source of Wealth Declaration;

  • Latest financial statement; and

  • Identification and verification of IDs of each director, controlling person and shareholder.

Note: List of KYC documents required subject to the types of investors.

This scope is designed for funds domiciled in the British Virgin Islands (“BVI”) and meets the AML rules and regulations set by the Financial Services Commission (“FSC”). The AML rules and regulations include such as Anti-Money Laundering Regulations, Anti-Money Laundering and Terrorist Financing Code of Practice, AML/CFT Policy, Proliferation Financing (Prohibition) Act, and the guidance notes on Anti-Money Laundering and Countering the Financing of Terrorism and Proliferation, each as amended from time to time. It may not be suitable for funds domiciled in other jurisdictions.

This scope of service is a supplemental service to support a BSA/AML program that is owned by the Client.

If contracted for KYC as a service, please note that Carta does not act as the Client’s BSA/AML Officer; supplemental Compliance Officer, and/or General Counsel.

The contracted service does not replace the need for an independent BSA/AML program owned by the Client.

This scope of service does not include nor does Carta provide guidance to the Client in regards to customer/investor risk, customer compliance, geographic risk, or compliance/legal ramifications of non-compliance to BSA or other applicable regulations. The Client owns the compliance risk and ultimately responsibility for their own BSA/AML program.

DISCLOSURE: This communication is on behalf of Carta Investor Services, Inc. ("Carta"), an affiliate of eShares Inc., d/b/a Carta, Inc. ("Carta, Inc."), and is not to be construed as legal, financial, accounting or tax advice; it is for informational purposes only. This communication is not intended as a recommendation, offer or solicitation for the purchase or sale of any security. Neither Carta nor Carta, Inc. assumes any liability for reliance on the information provided herein.