This Withdrawal and Transaction Monitoring Policy ("Policy") outlines the procedures and controls implemented by Vestra Inc. ("Vestra," "we," "us," or "our") to ensure the secure, compliant, and efficient processing of withdrawals and to monitor all transactions on its fractional real estate investment platform. This Policy is designed to comply with applicable anti-money laundering (AML), counter-terrorist financing (CTF), and financial regulations, as well as to protect Vestra and its users from fraudulent activities. This Policy is an integral part of Vestra's overall compliance framework and is subject to periodic review and updates to reflect changes in regulatory requirements and best practices.

1. Purpose and Scope

1.1. The primary purpose of this Policy is to establish a robust framework for managing withdrawal requests and monitoring all financial transactions conducted through the Vestra platform. This includes, but is not limited to, deposits, investments, profit distributions, and withdrawals. The Policy aims to:
(i) Ensure compliance with all relevant local, national, and international laws and regulations pertaining to financial transactions, including AML/CTF directives.
(ii) Protect Vestra and its users from financial crime, fraud, and illicit activities.
(iii) Maintain the integrity and security of the Vestra platform's financial operations.
(iv) Provide transparency regarding withdrawal processes, fees, and processing times.
(v) Facilitate efficient and timely processing of legitimate withdrawal requests.

1.2. This Policy applies to all users of the Vestra platform, including individual investors, institutional investors, and property sellers, as well as all Vestra employees involved in financial operations, compliance, and customer support.

2. Withdrawal Procedures

2.1. Initiation of Withdrawal Request:
* Users can initiate a withdrawal request through their Vestra account dashboard.
* The user must specify the withdrawal amount, the destination account (e.g., digital wallet, linked bank account, external crypto wallet, or other supported payment methods).
* Withdrawal requests are subject to the specific terms and conditions of the property schema from which profits are being withdrawn, including any lock-up periods or minimum withdrawal amounts.

2.2. Withdrawal Limits: Vestra may impose daily, weekly, or monthly withdrawal limits based on the user's verification level (KYC/KYB status), transaction history, and risk assessment. These limits are subject to change at Vestra's sole discretion and will be communicated to users through the platform.

2.3. Payout Processing Time:
(i) Automated Payouts: For automated withdrawal requests processed through integrated payment gateways, the processing time is typically instant to 60 minutes. This applies to withdrawals to verified bank accounts or supported digital wallets where automated systems are in place.
(ii) Manual Payouts: Manual payouts, which may be required for certain payment methods, larger amounts, or in cases of enhanced due diligence, may take longer. Users will be notified of the estimated processing time for manual payouts, which can range from 1 to 5 business days, depending on the destination and any intermediary bank processing times.
(iii) Cryptocurrency Payouts: Cryptocurrency withdrawals are generally processed within instant to 30 minutes for automated systems, but actual receipt time may vary depending on blockchain network congestion and confirmation times. Manual crypto payouts may take longer, similar to manual fiat payouts.

2.4. Destination Account Verification: 
* All withdrawal destination accounts must be pre-verified and linked to the user's Vestra account. Vestra reserves the right to request additional documentation to verify ownership of the destination account to prevent fraud and comply with AML regulations.
* Withdrawals can only be made to accounts held in the name of the Vestra account holder. Third-party withdrawals are strictly prohibited.

3. Withdrawal Fees

Vestra applies a structured fee schedule for withdrawal activities, which are charged quarterly and based on the total balance (including account balance and total assets under management). These fees are designed to cover operational costs, gateway charges, and compliance overheads.

3.1. Gateway Activation Fees (Fiat):
* Below $100: $10
* $101 - $1,000: $70
* $1,001 - $50,000: $130
* $50,000 and above: $180

3.2. Gateway Activation Fees (Crypto Gateways):
* Below $100: $15
* $101 - $1,000: $90
* $1,001 - $50,000: $180
* $50,000 and above: $220

3.3. Flat Fees (Both Crypto and Fiat):
* Below $100: $10
* $101 - $1,000: $60
* $1,001 - $50,000: $100
* $50,000 and above: $160

3.4. Processing Fees (Where Applicable): Vestra reserves the right to charge additional processing fees for certain transaction types or in cases of processing complications, {particularly for manual payouts.}
* 1.5% fee on standard fiat wallets and bank withdrawals.
* 1.8% fee on flagged or manual crypto payouts.

3.5. Fee Disclosure and Approval: All applicable charges, including gateway activation fees, flat fees, and processing fees, will be fully disclosed to the user prior to the final confirmation of any transaction. Vestra will never withdraw fees without your prior approval for the specific transaction.

3.6. Users in Some Platforms (e.g., Stripe, PayTM, Ognimohub, RazorPay, Revolut, CashApp, Zelle, Zillow, CBRE, JLL, Cushman & Wakefield, American Tower Corporation, Prologis, Simon Property Group, Digital Realty, Equinix, and Ventas) may enjoy certain percentage discounts or other fee reductions from the above-stated fees, as per the specific terms and policies of those respective firms. Users are advised to refer to the terms and conditions of these partner platforms for details on applicable discounts.

4. Transaction Monitoring

4.1. Automated Monitoring Systems: Vestra employs advanced automated transaction monitoring systems to detect and flag suspicious activities in real-time. These systems utilize rule-based logic, artificial intelligence (AI), and machine learning (ML) algorithms to analyze transaction patterns, user behavior, and historical data. Key indicators for suspicious activity include, but are not limited to:
(i) Large or unusual transaction amounts inconsistent with a user's profile.
(ii) Frequent transactions with high-risk jurisdictions.
(iii) Rapid movement of funds immediately after deposit or investment.
(iv) Transactions involving sanctioned entities or individuals.
(v) Unusual login patterns or access from suspicious IP addresses.
(vi) Multiple accounts linked to the same individual or IP address.

4.2. Manual Review and Enhanced Due Diligence (EDD): Transactions flagged by the automated monitoring systems, or those identified as high-risk through other means, will be subjected to manual review by Vestra's compliance team. During manual review, Vestra may conduct Enhanced Due Diligence (EDD), which can include:
* Requesting additional documentation from the user (e.g., source of funds, source of wealth, proof of transaction purpose).
* Conducting open-source intelligence (OSINT) checks.
* Verifying the identity of counterparties.
* Interviewing the user if necessary.
* Transactions under EDD may experience delays in processing. Vestra will communicate with the user regarding any delays and information requests.

4.3. Reporting Suspicious Activities: If, after review, a transaction is deemed suspicious and potentially indicative of money laundering, terrorist financing, or other illicit activities, Vestra's compliance team will file a Suspicious Activity Report (SAR) or equivalent report with the relevant financial intelligence unit (FIU) or regulatory authority, as required by law. Vestra will cooperate fully with law enforcement and regulatory bodies in their investigations.

4.4. Record Keeping: Vestra maintains comprehensive records of all transactions, withdrawal requests, and monitoring activities for a minimum period of five (5) years, or longer if required by applicable law or regulatory guidance. These records include transaction details, user identification data, and any communications related to suspicious activity.

5. Compliance with AML/CTF Regulations

5.1. Know Your Customer (KYC) and Know Your Business (KYB): Vestra implements a robust KYC/KYB program as described in its Terms of Service and Privacy Policy. All users must complete the required verification processes before engaging in significant financial transactions, including withdrawals. This involves collecting and verifying identity documents, proof of address, and other relevant information. For corporate entities or property sellers, KYB procedures involve verifying business registration documents, beneficial ownership, and corporate structure.

5.2. Sanctions Screening: All users and transactions are screened against relevant sanctions lists, including those maintained by the Office of Foreign Assets Control (OFAC), the United Nations Security Council, and other international bodies. Any matches will result in the immediate freezing of funds and reporting to the appropriate authorities.

5.3. Risk-Based Approach: Vestra adopts a risk-based approach to AML/CTF compliance, meaning that the intensity of due diligence and monitoring efforts is commensurate with the assessed risk level of the user, transaction, or jurisdiction.

6. Freezing and Blocking of Funds

6.1. Vestra reserves the right to freeze or block funds, suspend withdrawal requests, or terminate user accounts if:
* There is a reasonable suspicion of money laundering, terrorist financing, fraud, or other illicit activities.
* Required by a court order, regulatory directive, or law enforcement request.
* The user fails to provide requested information for due diligence or verification purposes.
* The user is identified on a sanctions list.

6.2. In such cases, Vestra will act in accordance with legal and regulatory obligations, which may include reporting to authorities without notifying the user.

7. User Responsibilities

7.1. Users are responsible for:
* Providing accurate and up-to-date personal and financial information.
* Ensuring the security of their Vestra account credentials.
* Promptly responding to any requests for additional information from Vestra's compliance team.
* Complying with all applicable laws and regulations related to their use of the Vestra platform.

8. Policy Review and Updates

8.1. This Policy will be reviewed at least annually, or more frequently if there are significant changes in regulatory requirements, business operations, or risk landscape.
8.2. Any updates to this Policy will be communicated to users through the Vestra platform or via email. Continued use of the platform after such updates constitutes acceptance of the revised Policy.