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Scope of Services: Due Diligence (UAE*)

This scope is designed for funds domiciled in the ADGM and meets the AML rules and regulations set by the Financial Services Regulatory Authority (“FSRA”). The AML rules and regulations include such as the Conduct of Business Rulebook which is 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.

*Regulated by the Financial Services Regulatory Authority in the ADGM

SERVICE

CARTA RESPONSIBILITIES

CLIENT RESPONSIBILITIES

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 25% or more interests, where applicable

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

Politically Exposed Person (PEP) list;

Applicable Sanctions list(s);

Enforcement list(s); and

Adverse media, as applicable.

Perform risk rating assessment on the investor


Periodic monitoring

Review refreshed KYC file and request updated documents, as applicable, to ensure an updated KYC file in relation to the current customer risk rating

Conduct screening

Perform a refresh of the existing risk rating assessment

Update Client on any change in the screening results and refreshed risk rating


Perform recurring screening of applicable parties during the valid 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.