Vestra, a fractional real estate company located at 1209 Orange Street, Wilmington, New Castle County, Delaware 19801, and operating globally, requires a robust Transaction Monitoring Policy to ensure compliance with anti-money laundering (AML) and counter-terrorist financing (CTF) regulations. This policy outlines the procedures for monitoring financial transactions to detect and prevent illicit activities, safeguarding Vestra's operations and reputation. The policy integrates various sub-policies, including Deposit, Withdrawal, Processing Fees, KYC Verification Fees, and Refund policies, to provide a comprehensive framework for managing financial flows and client interactions.

This comprehensive policy is designed to align with international best practices and regulatory requirements, such as those set forth by the Financial Crimes Enforcement Network (FinCEN) in the United States and the Financial Action Task Force (FATF) globally. It emphasizes a risk-based approach, meaning that the intensity of monitoring will be commensurate with the assessed risk of the transaction and the client involved. The goal is to create a secure and transparent environment for all participants in Vestra's fractional real estate investment ecosystem.

Transaction Monitoring

Vestra's Transaction Monitoring Policy is a critical component of its broader AML/CTF framework, designed to identify and report suspicious activities. This policy applies to all transactions conducted through Vestra's platform, including deposits, withdrawals, and any other financial movements related to fractional real estate investments. The monitoring process involves both automated systems and manual review by trained compliance officers.

Deposit Policy

Vestra's Deposit Policy outlines the procedures for clients to fund their investment accounts. All deposits must originate from accounts held in the name of the verified Vestra client. Third-party deposits are strictly prohibited to mitigate money laundering risks.

• Accepted Deposit Methods: Vestra accepts deposits via bank transfers (ACH/Wire), and potentially approved cryptocurrency transfers, subject to specific jurisdictional regulations and Vestra's internal risk assessment. The availability of specific methods may vary by region.
• Deposit Limits: Daily, weekly, and monthly deposit limits may be imposed based on the client's KYC verification level and Vestra's risk assessment. These limits are subject to change and will be communicated to clients through their account dashboard or direct notification.
• Source of Funds Verification: For significant deposits or those deemed high-risk, Vestra reserves the right to request additional documentation to verify the source of funds. This may include bank statements, tax returns, or other financial records.
• Deposit Confirmation: Upon successful deposit, clients will receive a confirmation email or notification within their Vestra account.

Withdrawal Policy

Processing Fees Policy

Vestra applies processing fees for certain transactions to cover operational costs associated with payment processing, network fees, and administrative overhead. These fees are transparently disclosed to clients before they initiate a transaction.

• Deposit Fees: While Vestra strives to minimize deposit fees, some methods, particularly international wire transfers or certain cryptocurrency transactions, may incur charges from intermediary banks or network providers. Any such fees will be clearly communicated.
• Withdrawal Fees: Vestra may apply a processing fee to certain withdrawal requests. The applicable fee is displayed within the payout interface and identified as “Withdraw Fee.” This fee represents the operational and administrative costs associated with processing withdrawals through specific payment gateways and must be paid externally from the same gateway and account receiving the payout. Withdrawal processing fees vary depending on the gateway selected by the user. Each gateway may impose its own charges or operational constraints; therefore, the Withdraw Fee may differ from one provider to another. Vestra does not determine or standardize these external fee structures. Withdrawal processing fees are not applied to payouts made through automatic gateways unless otherwise required by the gateway or applicable regulations. Processing fees must be settled before any withdrawal request can be approved. Once you initiate a withdrawal and it appears as pending, please complete the required processing feea as indicated in the withdrawal window. Kindly note that all processing fees are non-refundable.
• Transaction Fee Disclosure: All applicable processing fees will be displayed to the client on the transaction confirmation screen before the transaction is finalized. A detailed breakdown of fees will also be available in the client's transaction history.
• Fee Structure: Vestra's fee structure is subject to periodic review and adjustment. Clients will be notified of any changes in advance.

KYC Verification Fees Policy

Vestra is committed to maintaining a secure and compliant platform, which necessitates robust Know Your Customer (KYC) and Anti-Money Laundering (AML) procedures. While Vestra generally absorbs the costs associated with standard KYC verification, certain enhanced due diligence (EDD) processes or re-verification requests may incur a fee. For detailed information, please refer to Vestra's comprehensive KYC/AML Policy.

• Standard KYC: Initial KYC verification for all new clients is typically provided at no direct cost to the client. This includes identity verification, proof of address, and basic background checks.
• Enhanced Due Diligence (EDD) Fees: In cases where a client's risk profile necessitates EDD, such as for politically exposed persons (PEPs) or individuals from high-risk jurisdictions, Vestra may charge a fee to cover the additional costs of specialized checks and ongoing monitoring. These fees will be communicated to the client prior to commencing EDD.
• Re-verification Fees: If a client fails to provide updated documentation in a timely manner, or if multiple re-verification attempts are required due to incomplete or inaccurate submissions, a re-verification fee may be applied.
• Transparency: Any KYC verification fees will be clearly outlined and agreed upon with the client before they are incurred.

Refund Policy

Vestra's Refund Policy outlines the conditions under which clients may be eligible for a refund of funds or investments. This policy is designed to be fair and transparent, while also protecting Vestra from potential abuse. For a complete understanding of refund eligibility and procedures, please refer to Vestra's official Refund Policy.

• Investment Refunds: Refunds for fractional real estate investments are generally not permitted once an investment has been finalized, as these are illiquid assets. However, specific circumstances, such as a failed project or regulatory issues, may trigger a refund process as outlined in the investment agreement.
• Deposit Refunds: Deposits that have not yet been allocated to an investment may be eligible for a refund, subject to any applicable processing fees. The request for such a refund must be made within a specified timeframe, typically 24-48 hours of the deposit, and before any investment commitment.
• Processing of Refunds: Approved refunds will be processed back to the original source of funds to comply with AML regulations. The timeframe for receiving a refund will depend on the payment method and financial institutions involved.
• Dispute Resolution: Any disputes regarding refunds will be handled in accordance with Vestra's dispute resolution procedures, aiming for a fair and timely resolution.

Contact Information

For any inquiries related to transactions, policies, or support, clients can reach Vestra through the following channels:

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