Investor Review

Investor and Client Due Diligence

A risk-based approach to prospective investors, clients and business partners.

Review

Risk-Based Review

Altium Fund applies a risk-based approach to assessing prospective investors, clients and business partners. Our review covers identity, authorised representatives, beneficial ownership and control, the purpose of the relationship, and the source of funds and, where appropriate, wealth. We also conduct sanctions, politically exposed person and adverse-media screening, and assess investor eligibility under the relevant investment documentation.

Higher-risk relationships undergo enhanced due diligence and additional approval. Acceptance is subject to satisfactory completion of the review, with information updated and relationships monitored on an ongoing, risk-sensitive basis. Altium Fund may decline relationships that do not meet applicable legal requirements or its acceptance criteria.

Review sequence

From Identity to Ongoing Monitoring

01Identity
02Authorised Representatives
03Beneficial Ownership and Control
04Purpose of the Relationship
05Source of Funds and Wealth
06Sanctions, PEP and Adverse-Media Screening
07Investor Eligibility
08Risk Assessment
09Acceptance or Enhanced Due Diligence
10Ongoing Monitoring
Standard risk
  1. Standard Review
  2. Acceptance and Monitoring
Higher risk
  1. Enhanced Due Diligence
  2. Additional Approval
  3. Acceptance or Decline
Acceptance

Acceptance is subject to satisfactory completion of the review.

Compliance

Three Levels of Review

Responsibilities are separated so that collection, review and oversight do not rest with the same function.

First lineBusiness and onboarding
  • Identification documents
  • Corporate documents
  • Source-of-funds information
  • Initial completeness review
Second lineCompliance review
  • Sanctions screening
  • PEP screening
  • Adverse-media screening
  • Risk classification
  • Enhanced review where required
OversightApproval and control
  • Approval or escalation
  • Policy oversight
  • Record keeping
  • Periodic control review