Policy Statement and Commitment
Vespera Quantivus Corp is committed to preventing the misuse of its platform and investment vehicles for money laundering, terrorist financing, or other illegal financial activity. We maintain a compliance program consistent with the Bank Secrecy Act (BSA), applicable FinCEN regulations, and SEC guidance for investment advisers.
Know Your Client (KYC) Procedures
Before accepting any investor, Vespera Quantivus will collect and verify identifying information, including legal name, date of birth, residential address, and government-issued identification. All investors must provide evidence of accredited investor status under Regulation D of the Securities Act of 1933. We verify the source of funds for each investment and reserve the right to decline any investor relationship where documentation is incomplete, unverifiable, or raises concerns.
Internal Controls and Monitoring
We maintain internal procedures to monitor investor activity and identify suspicious patterns. These include a risk-based review of investor profiles, ongoing monitoring of capital flows, and escalation procedures for unusual activity. All suspicious activity is reported to the appropriate regulatory authority. We do not disclose investigations to the individuals under review. All investor records and transaction data are retained for a minimum of five years.
Enhanced Due Diligence
Enhanced customer due diligence is applied in high-risk situations, including investors identified as Politically Exposed Persons (PEPs), investors domiciled in jurisdictions with significant AML/CFT deficiencies, transactions or patterns that appear unusual or inconsistent with stated investment objectives, and any circumstances where the source of funds cannot be satisfactorily verified.
Employee Training
All personnel with investor-facing responsibilities receive AML/CFT training covering recognition of suspicious activity, internal reporting obligations, and applicable regulatory requirements. A designated Compliance Officer oversees this program and its ongoing effectiveness.
Policy Review
This policy is reviewed annually and updated as needed to reflect changes in applicable law, regulatory guidance, and internal business practices.
Contact Us
For compliance-related inquiries, please contact us at info@vesperaqv.com.