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Scope of Services: Due Diligence (BVI Funds)

Click below the table to download a PDF copy of the Due Diligence Screening and ID Verification Checklist for BVI Funds.

SERVICE

CARTA RESPONSIBILITIES

CLIENT RESPONSIBILITIES

Due Diligence Screening and ID Verification (BVI Funds)

Provide a Due Diligence report of findings to the Client with the following information within an estimated 3-5 business days of Carta receiving all necessary information from the Client:


Identification verification of individuals

  • U.S. ID verification against IRS TIN and third-party databases as well as documents provided by Client or

  • Non-U.S. ID verification against documents provided by Client

Initial sanction and watch list screenings

  • Politically Exposed Person (PEP) list

  • Sanctions list

  • Watch list

  • Enforcement list 

  • Adverse media

Review of entities

  • Entity information

  • Control person of entity

  • Individual beneficial owners with 10% or more ownership, as applicable

  • Verification of ID as described above

Perform Risk Rating Assessment on the investor.

Periodic Monitoring

  • Obtain and review updated CDD information

  • Re-perform risk rating assessment

  • Provide an update to the Client on any change in the screening and risk rating assessment.

Perform monthly screening of names for contract period.

Client (either through Client’s GP or Client’s legal counsel) must first provide Carta with all necessary information, as follows:


All documents provided should be certified as a true copy by an acceptable person and in the certification wording in accordance with the certification guidelines as described in the checklist*


For individuals:

  • Current passport or other valid government-issued photographic identification which includes the individual name, document identification number, expiry date, nationality, date and place of birth and the signature page (minimum 6 months validity)

  • Bank/credit card statement or utility bill dated within the past three months bearing residential address (not a mobile phone bill)

  • Current occupation and the industry the investor is dealing in

  • Information as to the Source of Funds for the commitment and Source of Wealth, to be completed by the investor*

  • The appropriate U.S. Internal Revenue Service (“IRS”) W-8 (non-US person) or W-9 (US person) tax withholding form. The most current versions of such forms may be downloaded at the following website: https://www.irs.gov/forms-pubs/about-form-w-8-ben https://www.irs.gov/forms-pubs/about-form-w-9

  • The CRS individual self-certification form*

For entities:

  • Certified copy of formation document

  • Name of the entity

  • Address

  • Confirmation regarding the origin of wealth, i.e. evidence of how the funds for the investment were accumulated

  • The appropriate U.S. Internal Revenue Service (“IRS”) W-8 (non-US person) or W-9 (US person) tax withholding form. The most current versions of such forms may be downloaded at the following website: https://www.irs.gov/forms-pubs/about-form-w-8-ben https://www.irs.gov/forms-pubs/about-form-w-9

  • The CRS Self-Certification form*

Client to provide Carta with individual information for beneficial owners with 10% or more ownership and one (1) control person for each entity LP:

  • Current passport or other valid government-issued photographic identification which includes the individual name, document identification number, expiry date, nationality, date and place of birth and the signature page (minimum 6 months validity)

  • Bank/credit card statement or utility bill dated within the past three months bearing residential address (not a mobile phone bill)

  • Current occupation and the industry the investor is dealing in

  • Information as to the Source of Funds for the commitment and Source of Wealth, to be completed by the investor*

  • The appropriate U.S. Internal Revenue Service (“IRS”) W-8 (non-US person) or W-9 (US person) tax withholding form. The most current versions of such forms may be downloaded at the following website: https://www.irs.gov/forms-pubs/about-form-w-8-ben https://www.irs.gov/forms-pubs/about-form-w-9

  • The CRS individual self-certification form*

**All Carta SLAs exclude public holidays and office closures. Expedited service may be provided for an additional fee.  

Please note: If the expedite service is added, the delivery time will be an estimated  2-3 business days from when documentation is provided to Carta 

This scope  is designed for funds domiciled in the US and  meets the  U.S. standards for Anti-Money Laundering (AML) and Know Your Customer (KYC) identity verification. 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.

BVI Checklist.pdf
4.2 MB