AML and KYC, carried out by a regulated firm.
As a MiFID-regulated firm we carry out AML and KYC on every investor in the funds whose share units we hold in custody or for which we act as transfer agent. For any other fund, we carry it out on the fund’s behalf under a contractual mandate. For a tokenised share class that check does more than open an account: its outcome is what decides which wallets are permitted to hold the shares.
From AML/KYC file to wallet eligibility.
Onboarding is the first step. What makes AML/KYC durable here is that its outcome stays attached to the wallet holding the shares.
Identity, ownership structure and source of funds, gathered through your channel or ours.
Sanctions, politically exposed person and adverse media checks, run against the official watchlists we are required to screen against.
A risk profile and an approval, documented in a form a regulatory supervisor can inspect.
The approved investor’s wallet becomes permitted to hold the share class.
Ongoing screening and periodic review. Eligibility can be withdrawn if the picture changes.
A supervised firm carries out the AML/KYC.
We already carry out AML and KYC as a MiFID-regulated firm. On a tokenised share class the result is built into the token and the wallet, so a wallet that has not been cleared cannot receive the shares.
Launching a share class or fund does not require building a new AML/KYC and screening operation for it. Anti-money-laundering obligations are the same whether the share class is tokenised or not, and we carry them out as a regulated firm.
On a permissioned standard, only wallets we have cleared and whitelisted can receive the token. The restriction travels with the share and the wallet.
An investor cleared through AML/KYC once can be recognised across the distributors routing to you, on agreed reliance terms.
AML/KYC documents, decisions and screening results are retained in the form the CSSF expects to see them.
AML/KYC sits with us. Advice stays with the distributor.
We carry out AML/KYC and the monitoring that follows it. Advice remains with the asset manager and its distributors, as do their own reporting obligations. Suitability can be shared, depending on how distribution is set up.
Nothing moves before AML/KYC clears the investor.
Every investor service runs against the same on-chain register, operated by the same regulated firm. So adding one does not mean connecting another system.
Answered in advance.
Who carries the AML / KYC responsibility?+
Investre can take on AML / KYC responsibility itself where it provides the digital wallet, as custodian, or acts as transfer agent. In all other cases, Investre carries out AML / KYC under a contractual mandate from the fund.
Can we rely on our distributor’s checks?+
Often yes, under a written reliance arrangement. We review the distributor’s programme first, because the outcome remains ours to defend.
Which entity is responsible?+
It depends on the role. As transfer agent, Investre is legally required to carry out AML/KYC on the fund’s investors. As control agent, Investre has no such legal obligation as such, but carries out AML/KYC services for the fund on a contractual basis.
What happens if an investor’s status changes?+
Ongoing screening raises it, the file is reviewed, and eligibility can be suspended. On a permissioned share class that halts further transfers without the fund having to act.
Where is investor data held?+
In the European Union, under GDPR, with retention periods set by the Luxembourg AML regime.
Bring the investor type you find hardest to clear.
A nominee arrangement, a trust, an investor in a market you have avoided. We will tell you what AML/KYC on it actually involves.
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