Scope of Services: US Due Diligence (US OFAC Sanctions Only)

Service

Carta Responsibilities

Client Responsibilities

Due Diligence Screening - OFAC Sanctions Only for U.S. based Funds

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

Initial sanctions watch list screening

Investors reviewed as part of this service will be screened against the OFAC SDN (Specially Designated National & Blocked Persons) watch list.

Perform recurring screening of names against the above sanctions watch list.

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

For individuals:

Name
Title
Personal address
Date of birth
Government-issued ID number (SSN for U.S. individuals)
Non-expired government-issued photo ID (not required for U.S. individuals if SSN provided, required for non-U.S. individuals for verification).

For entities:

Formation documents
Name
Address
Government-issued ID number (EIN for U.S. entities).

Client to provide Carta with individual information for beneficial owners with 25% or more ownership and one (1) control person for entity LPs:

Name
Title
Personal address
Date of birth
Government-issued ID number (SSN for U.S. individuals)
Non-expired government-issued photo ID (not required for U.S. individuals if SSN provided, required for non-U.S. individuals for verification).

*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.