Scope of Services: Security Holder Due Diligence (U.S. Portfolio Companies)

Service

Carta Responsibilities

Client Responsibilities

Security Holder Due Diligence Screening and ID Verification (U.S. Portfolio Company)

Provide the Client with a comprehensive report of findings, including the verification of Security Holder identities through documentary and non-documentary reviews, complemented by real-time screening results from global sanctions, PEP, enforcement, and adverse media watchlists.

The report will be issued within an estimated 3-5 business days* of Carta receiving all necessary information from Client and/or the relevant Security Holders.

Carta will only perform screening on specific Security Holders as requested by Client.

Identification document verification of individuals
- U.S. ID verification: With IRS Taxpayer Identification Number and third-party databases as well as valid government-issued photo ID (e.g. passport, driver license) provided by Client.
- Non-U.S. ID verification: With valid government-issued photo ID provided by Client.
Review of entities
- Entity information
- Control person of entity
- Individual beneficial owners with 25% or more ownership, as applicable
- Verification of ID as described above.
Initial sanction and watch list screenings
- Politically Exposed Person (PEP) list
- Sanctions lists (OFAC and international lists)
- Adverse media (inclusive of Enforcement list and Watch list)
Ongoing Monitoring
- Perform daily recurring screening of applicable parties (inclusive of PEP, Sanctions, and Adverse Media)
- Notify Client of any material findings identified from daily recurring screening

Client must identify Security Holders for Carta to screen.

Client (either through Client, Client's legal counsel, or Security Holder directly) must first provide Carta with all necessary Security Holder information, as follows:

For individuals:

Name
Personal Residence Address
Date of Birth
Taxpayer Identification Number (SSN for U.S. individuals)
Valid government-issued photo ID (must not be expired)

For entities:

Name of entity
Address
Formation document(s)
Taxpayer Identification Number (EIN for U.S. entities)
Beneficial Owner Info: Client to provide Carta with information for beneficial owners, which includes all individual or entity owners with 25% or more direct or indirect ownership and at least 1 control person (including Full Legal Name, Personal Residence Address, Date of Birth, and Government-Issued Photo ID). Carta may require supplemental data on beneficial ownership for complex, multi-tiered structures.

Important Notes and Disclaimers

SLAs: All Carta SLAs exclude public holidays and office closures.
U.S. Scope Only: This scope is designed for funds domiciled in the U.S. to meet U.S. standards for AML and KYC identity verification. It may not be suitable for AML/KYC requirements in other jurisdictions.
Not a Replacement for a Full Compliance Program: This is a supplemental service to support the Client’s own BSA/AML program. Carta does not act as the Client's BSA/AML Officer, Compliance Officer, or Legal Counsel. This service does not replace the need for an independent BSA/AML program owned by the Client.
Client’s Risk Assessment: Carta does not provide guidance regarding customer/investor risk, geographic risk, or legal or regulatory consequences of non-compliance. The Client is solely responsible for AML compliance decisions and their own AML compliance program in general.
No Provision of Enhanced Due Diligence (EDD): The Client is responsible for evaluating results and performing enhanced due diligence on LPs as the Client sees fit.

Legal Disclosure

This communication is on behalf of eShares Inc. dba 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. Carta assumes no liability for reliance on the information provided herein.