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SERVICE

CARTA RESPONSIBILITIES

CLIENT RESPONSIBILITIES

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

Carta will provide the following AML/KYC services, 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 Singapore and  meets the AML rules and regulations set by the Monetary Authority of Singapore (“MAS”).  The AML rules and regulations include such as MAS Notices on Prevention of Money Laundering and Countering the Financing of Terrorism, Guidelines to MAS Notice on Prevention of Money Laundering and Countering the Financing of Terrorism, Corruption, Drug Trafficking and other Serious Crimes (Confiscation of Benefits) Act (Chapter 65A), Terrorism (Suppression of Financing) Act.   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.