Scope of Services: Investor KYC Due Diligence (Cayman Based Funds)
This document outlines what information Carta collects, what Carta performs, and what the client is responsible for providing when conducting Know Your Customer (KYC) due diligence for Cayman-based funds.
Service | Carta responsibilities | Client responsibilities |
Due Diligence Screening & Identity Verification Cayman-Based Funds | Provide the Client with a comprehensive report of findings (“due diligence report”) on Customer Due Diligence (“CDD”), including the verification of investor identities through documentary and non-documentary reviews, complimented 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 investor. Carta will only perform screening on specific investors as requested by Client. Identity Verification Review for 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.
Identity Verification Review of Entities Entity information Control person of entity Individual beneficial owners with 10% or more ownership, as applicable Verification of identification as described above
Sanctions & Watch List Screening Risk Assessment | Client to notify Carta on investors to be screened. Client to initiate screening of investors via in-app product (or manual). . Client (either through Client, Client's legal counsel, or investor directly) must first provide Carta with all necessary investor information, as follows: Individuals Valid government-issued photo ID (e.g., passport) — must not be expired — which includes full name, document ID number, expiry date, nationality, date and place of birth, and signature page Proof of address (e.g., utility bill or bank statement) dated within the past 3 months — P.O. Box, credit card bills, and mobile phone bills are not acceptable Source of Funds and Source of Wealth declaration — describing origin of funds for the investment in detail (not generic descriptions) Completed U.S. IRS W-8 tax withholding form (appropriate version for individual type) Completed CRS Self-Certification form (individual version) – applicable to non-US clients only
Entities (Corporations) Certified copy of Certificate of Incorporation (including any name changes) Certified copy of Memorandum and Articles of Association / Constitution Certified copy of Certificate of Incumbency / Good Standing Certified copy of Register of Directors Certified copy of Register of Shareholders Certified copy of structure chart showing all shareholders with 10%+ direct or indirect interest, including country of residence/incorporation and percentage ownership Certified copy of board resolution approving the investment Certified copy of authorized signatory list with specimen signatures and signing authority (not more than 1 year old) Description of nature, purpose, and industry of the business Source of Funds and Source of Wealth declaration Completed U.S. IRS W-8 tax withholding form (entity version) Completed CRS Self-Certification form (entity version) – applicable to non-US clients only KYC documents as outlined for each entity type for control person(s) and beneficial owner(s)
Limited Partnership Investors Certified copy of Certificate of Registration (including any name changes) Certified copy of the Limited Partnership Agreement (LPA) Certified copy of Certificate of Good Standing Certified copy of structure chart detailing all Limited Partners/Shareholders with 10%+ direct or indirect interest, including country of residence/incorporation Certified copy of board resolution approving the investment Certified copy of Register of Limited Partners (including the General Partner) Certified copy of authorized signatory list with specimen signatures and signing authority (not more than 1 year old) Description of nature, purpose, and industry of the business Source of Funds and Source of Wealth declaration Completed CRS Self-Certification form (entity version) – applicable to non-US clients only KYC documents as outlined for each entity type for control person(s) and beneficial owner(s)
Trust Investors Certified copy of structure chart detailing all settlors, protectors, beneficiaries, and trustees, including country of residence/incorporation Certified copy of the current Trust Deed and Declaration of Trust, including: trust name, date and jurisdiction of establishment, trustee powers, details of settlor, beneficiaries, and any protectors or controllers, and the signature page with seal Certified copy of authorized signatory list with specimen signatures and signing authority (not more than 1 year old) Description of nature, purpose, and objectives of the entity (e.g., discretionary, testamentary) Certified copies of passport (min. 6 months validity) and proof of address (dated within 3 months) for: all trustees, all settlors, any protectors or controllers, any beneficiary with a vested interest Source of Funds and Source of Wealth declaration Completed CRS Self-Certification form (entity version) – applicable to non-US clients only
Regulated / Listed Entity Investors Certified copy of Certificate of Incorporation Certified copy of board resolution authorizing the investment Evidence that the entity is regulated by a national financial regulator in an approved jurisdiction, or is listed on a recognized stock exchange Certified copy of authorized signatory list with specimen signatures and signing authority (not more than 1 year old) Certified copies of passport (min. 6 months validity) and proof of address (dated within 3 months) for all authorized signatories Completed CRS Self-Certification form (entity version) – applicable to non-US clients only
For each individual beneficial owner / control person: For each corporate beneficial owner: |
Periodic Review | Obtain and review updated CDD information Re-perform risk rating assessment Perform monthly screening of investor names for the duration of the contract Notify Client of any changes to the screening results or risk rating assessment
| Provide updated investor information and documents upon Carta's request Notify Carta of any material changes to investor structure, ownership, or status
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Important Notes
Document Language: All Entity KYC documents must be in English or translated into English by a certified translator.
Additional Requests: Carta may request additional information or documents during the CDD review as deemed necessary to verify investor identity.
Certification: Certified copies must be certified by an eligible certifier (e.g., lawyer, notary, regulated financial institution officer, embassy officer). Self-certification is not accepted. Documents certified must be dated within 3 months of submission.
Source of Funds / Source of Wealth: Additional confirmation of Source of Funds may be required in certain circumstances. Declarations must be substantive and specific — generic descriptions such as “business interests” or “shareholders” are not sufficient.
This scope is designed for funds domiciled in the Cayman Islands and complies with AML rules and regulations set by the Cayman Islands Monetary Authority (“CIMA”). The AML rules and regulations include such as Cayman Islands Anti-Money Laundering Regulations, Proceeds of Crime Act, Terrorism Act, the Proliferation Financing (Prohibition Act) and the guidance notes on the Prevention and Detection of Money Laundering, each as amended from time to time. It may not be suitable for funds domiciled in other jurisdictions. This is a supplemental service to support an AML program that is owned by the Client. Carta does not act as the Client’s AML officer, compliance officer, or legal counsel. This service does not replace the need for the client to have a full AML compliance program. Carta does not provide guidance to the Client regarding customer/investor risk, customer compliance, geographic risk, or legal or regulatory implications of non-compliance with applicable AML laws or regulations.
DISCLOSURE: This communication is on behalf of eShares, Inc. dba Carta, Inc. ("Carta") 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 does not assume any liability for reliance on the information provided herein.
