Last Updated: 10th Dec, 2025

Vestra, a fractional real estate company based in Wilmington, Delaware, operating worldwide, is committed to maintaining the highest standards of Know Your Customer (KYC) and Anti-Money Laundering (AML) compliance. This policy outlines the procedures and controls Vestra will implement to prevent its services from being used for illicit activities, such as money laundering and terrorist financing. The real estate sector is particularly vulnerable to money laundering due to its lucrative investment opportunities and the potential for criminals to integrate illicit funds into the system, often through cash transactions or shell companies.

Vestra recognizes that robust due diligence is not merely a regulatory obligation but a critical measure to safeguard its reputation and ensure the integrity of its operations. The company understands the importance of identifying and reporting suspicious activity (SAR) and will ensure all relevant personnel are appropriately trained to do so.

This policy is designed to align with international AML directives and best practices, including those outlined in the 4th and 5th Anti-Money Laundering Directives, and guidance from bodies like the Financial Action Task Force (FATF).

Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD)

Vestra will implement comprehensive CDD measures for all clients before entering into a business relationship, encompassing both buyers and sellers in fractional real estate transactions. This includes:

• Identity Verification: Confirming the identity of all clients, including individuals and the ultimate beneficial owners (UBOs) of corporate entities. This will involve obtaining reliable, independent source documents, data, or information.
• Source of Funds (SoF) and Source of Wealth (SoW): Investigating the origin of funds used in transactions, especially for high-value or cash transactions, to ensure they are legitimate and not derived from illicit activities.
• Business Relationship Understanding: Gaining a clear understanding of the nature and purpose of the business relationship, including the type of products and services involved, to assess potential risks.
• Politically Exposed Persons (PEPs) and Sanctions Screening: Conducting thorough checks for PEPs, individuals on sanctions lists, and adverse media mentions. Vestra's Global AML platform will provide instant results for these screenings.
• Ongoing Monitoring: Continuously monitoring business relationships, particularly for high-risk transactions or those involving high-risk jurisdictions, to detect any unusual or suspicious activity.

For situations presenting a higher risk of money laundering or terrorist financing, Vestra will apply Enhanced Due Diligence (EDD) measures. This may include obtaining additional information on the customer, the UBO, the source of funds/wealth, and the reasons for the intended or performed transactions.

Risk-Based Approach

Vestra will adopt a risk-based approach to AML compliance, allowing for the allocation of resources proportionate to the identified risks. This involves:

• Risk Assessment: Conducting a company-wide AML evaluation to identify and assess the money laundering and terrorist financing risks associated with its operations, customer types, geographic areas, products, services, and delivery channels.
• Risk Mitigation: Implementing appropriate controls and procedures to mitigate the identified risks. This includes adjusting the level of CDD and ongoing monitoring based on the assessed risk level of each client and transaction.
• Regular Review: Periodically reviewing and updating the risk assessment to reflect any changes in the business environment, regulatory landscape, or emerging threats.

Reporting Suspicious Activity

Vestra is committed to promptly reporting any suspicious activity to the relevant authorities. This includes:

• Appointing a Money Laundering Reporting Officer (MLRO): A nominated officer will be appointed and provided with suitable resources to carry out their function, including receiving and evaluating internal suspicious activity reports.
• Internal Reporting Procedures: Establishing clear internal procedures for employees to report any suspicious activity or transactions to the MLRO.
• External Reporting: The MLRO will be responsible for submitting Suspicious Activity Reports (SARs) to the appropriate financial intelligence unit (e.g., FinCEN in the US, National Crime Agency in the UK) in a timely manner.
• No Tipping-Off: Employees will be strictly prohibited from "tipping off" clients or third parties about any internal or external reporting of suspicious activity.

Training and Awareness

Vestra recognizes that effective AML compliance relies on a well-informed workforce. Therefore, the company will:

• Mandatory Training: Provide regular and mandatory AML training to all relevant employees, including sales teams, administrative staff, and management.
• Training Content: Training will cover the latest AML regulations, typologies of money laundering in the real estate sector, Vestra's internal policies and procedures, and how to identify and report suspicious activity.
• Continuous Education: Ensure that training programs are regularly updated to reflect changes in legislation, emerging risks, and best practices.

Record Keeping

Vestra will maintain accurate and comprehensive records of all customer due diligence, transaction monitoring, and suspicious activity reports in accordance with applicable data protection regulations, such as GDPR 2018. These records will be retained for the legally required period and made available to regulatory authorities upon request.

KYC Verification Levels

Vestra offers a tiered KYC verification system, where each tier unlocks higher transaction limits and enhanced features, reflecting an increased level of due diligence.

1. Tier 1: Basic KYC (Free)

This foundational tier is designed for new users to begin their fractional real estate investment journey with minimal initial friction, while still adhering to essential identity verification standards.

Verification Requirements:

• Full Legal Name: Submission of the client's complete legal name.
• Date of Birth: Provision of the client's date of birth to confirm age eligibility.
• Nationality: Declaration of the client's nationality.
• Valid Government-Issued Identification Document: Submission of a clear, legible copy of a valid government-issued ID, such as a passport, national ID card, or driver's license. This information is cross-referenced against official databases to confirm identity and detect inconsistencies.

Account Limits:

• Maximum Total Account Value: 0-$500
• Deposits: Up to $100
• Withdrawals: Up to $500
• Investments: Up to 2 shares reinvestment allowed after maturity.
• Send Money: Up to $100
• Priority Support: No

2. Tier 2: Verified Investor ($10 USD Per session)

Building upon Tier 1, this tier enhances security and trust through liveness detection, allowing for increased transaction capabilities and mitigating identity fraud risks.

Verification Requirements:

• Basic KYC: Completion of all Tier 1 requirements.
• Liveness Check KYC: In addition to Basic KYC, the client will undergo a real-time liveness detection process. This typically involves a selfie video or photo, which is analyzed to confirm that the person presenting the ID is indeed the legitimate owner and is physically present, helping to prevent identity fraud and spoofing.

Account Limits:

• Maximum Total Account Value: $501-$1,000
• Deposits: Up to $200
• Withdrawals: Up to $1,000
• Investments: Up to 5 shares reinvestment allowed after maturity.
• Send Money: Up to $200
• Priority Support: No

3. Tier 3: Advanced Investor ($25 USD per session)

This tier is for investors seeking higher transaction volumes and a more robust level of security. It introduces advanced verification methods to further mitigate risks and ensure compliance with age-related regulations.

Verification Requirements:

• Verified Investor KYC: Completion of all Tier 2 requirements.
• Adaptive Age Estimation and Questionnaire: This technology analyzes facial features from the submitted ID and liveness check to estimate the client's age, ensuring compliance with age-restricted services and adding another layer of identity verification. Additionally, a questionnaire may be administered to gather further information relevant to risk assessment.

Account Limits:

• Maximum Total Account Value: $1,001 - $10,000
• Deposits: Up to $1,000
• Withdrawals: Up to $10,000
• Investments: Up to 20 shares reinvestment allowed after maturity.
• Send Money: Up to $1,000
• Priority Support: Limited Priority Support

4. Tier 4: Premium Investor ($50 USD)

Designed for serious investors, this tier offers significantly higher limits and incorporates comprehensive AML screening to ensure compliance with global financial regulations and identify potential risks associated with Politically Exposed Persons (PEPs) or sanctioned entities.

Verification Requirements:

• Advanced Investor KYC: Completion of all Tier 3 requirements.
• AML Screening: Comprehensive screening against global watchlists, sanctions lists (e.g., OFAC sanctions lists, FATF blocklists), and databases of Politically Exposed Persons (PEPs). This helps identify individuals who may pose a higher risk for money laundering or terrorist financing.
• Proof of Address: Submission of a document verifying the client's residential address, such as a utility bill, bank statement, or rental agreement, typically dated within the last three months.

Account Limits:

• Maximum Total Account Value: $10,001 - $100,000
• Deposits: Up to $10,000
• Withdrawals: Up to $50,000
• Investments: Up to 100 shares reinvestment allowed after maturity.
• Send Money: Up to $10,000
• Priority Support: Limited Priority Support

5. Tier 5: Elite Investor ($75 USD)

Our highest tier offers the maximum possible transaction limits and the most stringent security measures, including biometric authentication and account ownership verification, for our most active and high-value investors. This tier aligns with Enhanced Due Diligence (EDD) requirements for higher-risk clients and transactions.

Verification Requirements:

• Premium Investor KYC: Completion of all Tier 4 requirements.
• Biometric Authentication: Utilization of unique physical characteristics, such as fingerprints or advanced facial recognition, for identity verification, providing an additional layer of security.
• Account Ownership Verification (Email and Phone): Verification of email address and phone number ownership to confirm control over associated communication channels. This may involve sending verification codes or conducting calls to confirm identity.

Account Limits:

• Maximum Total Account Value: $100,001 - $1,000,000
• Deposits: Up to $100,000
• Withdrawals: Up to $1,000,000
• Investments: Up to 500 shares reinvestment allowed after maturity.
• Send Money: Up to $100,000
• Priority Support: 24/7 dedicated phone and email support, with a dedicated account manager of your choice.

General Principles and Practices

Vestra's overall AML/KYC framework is built upon international best practices and regulatory guidelines, including those from the Financial Action Task Force (FATF), which designates real estate as a high-risk sector as stated in the introduction of this page.

• Risk-Based Approach: Vestra adopts a risk-based approach to AML/KYC, meaning that the intensity of due diligence is proportional to the assessed risk of money laundering or terrorist financing associated with a client or transaction. Factors considered in risk assessment include geographic location, transaction value, and ownership structures.
• Customer Due Diligence (CDD): For all clients, Vestra conducts CDD, which involves verifying client identities, understanding the nature of their business, and assessing the purpose of the transactions. This includes identifying the Ultimate Beneficial Owner (UBO) for corporate entities, as opaque ownership structures are a common money laundering red flag.
• Enhanced Due Diligence (EDD): For higher-risk clients or transactions (e.g., those involving PEPs, high-value cash transactions, or complex cross-border structures), Vestra applies EDD. This involves gathering additional information, such as the source of wealth and funds, and conducting more extensive background checks.
• Source of Funds Verification: Vestra requires clients to provide documentation to verify the legitimate source of their funds, especially for significant transactions. This helps prevent the integration of illicit proceeds into the fractional real estate ecosystem.
• Transaction Monitoring: Vestra employs ongoing transaction monitoring to detect unusual or suspicious patterns of activity that may indicate money laundering. This includes flagging large cash payments, frequent changes in ownership, or transactions significantly above or below market value.
• Recordkeeping: All KYC and AML records, including identification documents, transaction data, and risk assessments, are retained for a minimum of five years after the termination of the client relationship or the completion of a transaction, as required by regulations.
• Suspicious Activity Reporting (SARs): Vestra is obligated to report any suspicious activities or transactions to the relevant financial intelligence units (FIUs) in the jurisdictions where it operates.
• Internal Controls and Training: Vestra maintains robust internal AML policies, procedures, and controls. All relevant employees receive regular training on AML/KYC regulations, red flags, and reporting procedures to ensure ongoing compliance and readiness for regulatory inspections.
• Technology Integration: Vestra leverages advanced RegTech solutions, including AI and machine learning, for identity verification, document authentication, sanctions screening, and transaction monitoring. This automation enhances accuracy, speeds up onboarding, reduces human error, and ensures consistent application of compliance rules.

Consequences of Non-Compliance

Failure to comply with Vestra's KYC/AML policy or providing false information will result in immediate suspension or termination of account services. Vestra reserves the right to report suspicious activities to relevant authorities, which may lead to legal penalties, fines, and asset forfeiture for the individuals involved.

Technology and Outsourcing

Vestra will leverage technology to enhance its AML compliance efforts. Its Global AML platform will facilitate efficient screening for PEPs, sanctions, and adverse media.

While Vestra will primarily conduct AML checks in-house, recognizing the complexities and potential issues associated with outsourcing to third-party solicitors (such as contractual limitations with data providers and "soft footprint" concerns), the company may utilize specialized compliance service providers for certain aspects of its AML program, such as global compliance coordination, where appropriate and legally permissible. Any such outsourcing will be subject to rigorous due diligence and contractual agreements to ensure compliance with all applicable regulations and data privacy laws.

Compliance Officer and Oversight

Vestra will designate a Compliance Officer responsible for overseeing the implementation and effectiveness of this KYC/AML policy. The Compliance Officer will regularly review the policy and procedures, conduct internal audits, and ensure that Vestra remains compliant with all relevant national and international AML regulations.

Contact Information

For any inquiries regarding Vestra's KYC/AML policy, please contact:

Email: support@vestra.club Phone: +1(720) 580-1051 WhatsApp: +63 946 449 8012