INVESTOR DUE DILIGENCE
Review of investor details, source of wealth and source of funds
Collection and ongoing maintenance of required AML due diligence documentation.
Enhanced due diligence, senior management review and sign off for politically exposed persons (“PEPs”) or other higher risk investor profiles. Regular monitoring and follow up on outstanding AML due diligence documentation.
RISK ASSESSMENT AND ONGOING INVESTOR SCREENING
- Screening performed against the World-Check data file, fully integrated with the Investor Services platform, Mantra
- World-Check monitors over 400 sanctions lists, watch-lists, regulatory and law enforcement information sources, including OFAC, EU, UN and UK HMT
- Investors are screened against World-Check upon initial subscription and on a weekly basis
- Each investor risk assessment takes account of screening results, investor type/complexity and jurisdiction
- Ongoing due diligence and risk reviews occur at a frequency determined by the risk rating assigned to the investor following the risk assessment process.
- Ongoing monitoring of outstanding AML due diligence and risk ratings
- Quarterly testing of records for compliance with AML regulations and adherence to internal policies and procedures
- Review of the effectiveness of AML systems and controls
- Ongoing client communication regarding AML compliance
- Initial and ongoing communication with investors to secure AML compliance
- Provision of AML certifications and representations to third parties, upon request.
- Monthly client reporting on investor AML status
- AML risk and compliance reporting at each Fund board meeting.