Compliance Framework

1. Securities Law Compliance

1.1 United States Securities Regulations

Authenta Invest operates in full compliance with U.S. federal securities laws, including:

• Securities Act of 1933: All offerings comply with registration requirements or applicable exemptions under Regulation D, Regulation S, or Rule 144A
• Investment Company Act of 1940: Fund structure designed to avoid registration requirements while maintaining appropriate investor protections
• Investment Advisers Act of 1940: Investment advisory activities conducted in accordance with applicable registration and fiduciary requirements
• Commodity Exchange Act: Compliance with CFTC regulations where applicable to derivative instruments

1.2 International Securities Compliance

Our global operations maintain compliance with international securities regulations:

• European Union: MiFID II, AIFMD, and GDPR compliance for EU operations and investors
• United Kingdom: FCA regulations and post-Brexit regulatory framework compliance
• Asia-Pacific: Compliance with SFC (Hong Kong), MAS (Singapore), and other regional regulatory requirements
• Emerging Markets: Local securities law compliance in key emerging market jurisdictions

2. Anti-Money Laundering (AML) and Know Your Customer (KYC)

2.1 AML Program

Our comprehensive AML program includes:

• Customer Due Diligence (CDD): Rigorous identity verification and background screening for all investors
• Enhanced Due Diligence (EDD): Additional scrutiny for high-risk investors, politically exposed persons (PEPs), and complex ownership structures
• Ongoing Monitoring: Continuous transaction monitoring and periodic customer review processes
• Suspicious Activity Reporting: Prompt identification and reporting of suspicious transactions to relevant authorities

2.2 KYC Procedures

Our KYC framework encompasses:

• Identity Verification: Government-issued ID verification using advanced document authentication technology
• Address Verification: Proof of residence confirmation through utility bills, bank statements, or government correspondence
• Source of Funds: Documentation and verification of the legitimate source of investment funds
• Beneficial Ownership: Identification and verification of ultimate beneficial owners for corporate and trust investors

3. Data Protection and Privacy Compliance

3.1 Global Privacy Regulations

We maintain compliance with major data protection frameworks:

• GDPR (General Data Protection Regulation): Full compliance with EU data protection requirements
• CCPA (California Consumer Privacy Act): Compliance with California privacy rights and disclosure requirements
• PIPEDA (Canada): Adherence to Canadian personal information protection standards
• LGPD (Brazil): Compliance with Brazilian data protection legislation

3.2 Data Security Measures

Our data protection infrastructure includes:

• Encryption: End-to-end encryption for data in transit and at rest using AES-256 standards
• Access Controls: Multi-factor authentication and role-based access control systems
• Data Minimization: Collection and retention of only necessary personal information
• Incident Response: Comprehensive data breach response procedures and notification protocols

4. Operational Risk Management

4.1 Risk Management Framework

Our enterprise risk management approach covers:

• Market Risk: Comprehensive monitoring and mitigation of copyright market volatility
• Credit Risk: Due diligence and ongoing monitoring of counterparty creditworthiness
• Operational Risk: Process controls, technology safeguards, and business continuity planning
• Legal Risk: Ongoing legal compliance monitoring and regulatory change management

4.2 Internal Controls

Robust internal control systems include:

• Segregation of Duties: Clear separation of trading, operations, and oversight functions
• Independent Oversight: Independent board oversight and third-party risk assessments
• Documentation: Comprehensive policies, procedures, and audit trails
• Regular Testing: Periodic testing and validation of control effectiveness

5. Tax Compliance

5.1 International Tax Framework

Our tax compliance strategy encompasses:

• FATCA Compliance: Full compliance with U.S. Foreign Account Tax Compliance Act requirements
• CRS Reporting: Automatic exchange of information under OECD Common Reporting Standard
• Transfer Pricing: Arm's length pricing for intercompany transactions and services
• Withholding Tax: Proper withholding and remittance of taxes on international royalty flows

5.2 Investor Tax Considerations

We provide comprehensive tax support including:

• Tax Reporting: Timely provision of required tax documents (K-1s, 1099s, etc.)
• Tax Optimization: Structure optimization to minimize tax burden within legal boundaries
• Professional Advice: Access to qualified tax professionals for investor consultation
• Multi-Jurisdictional: Support for investors across multiple tax jurisdictions

6. Technology and Cybersecurity Compliance

6.1 Cybersecurity Standards

Our cybersecurity framework aligns with industry best practices:

• SOC 2 Type II: Annual third-party audits of security, availability, and confidentiality controls
• ISO 27001: Information security management system certification
• NIST Framework: Implementation of NIST Cybersecurity Framework controls
• Zero Trust Architecture: Implementation of zero trust security principles

6.2 Technology Governance

Technology risk management includes:

• Change Management: Formal change control processes for system modifications
• Vendor Management: Comprehensive third-party risk assessment and monitoring
• Business Continuity: Disaster recovery and business continuity planning
• Regular Updates: Systematic security patching and system maintenance

7. Regulatory Reporting and Transparency

7.1 Regulatory Filings

We maintain timely and accurate regulatory reporting:

• Form ADV: Investment adviser registration and disclosure documents
• Form PF: Private fund reporting to SEC and CFTC
• AIFMD Reporting: Alternative Investment Fund Manager reporting in EU
• Local Filings: Jurisdiction-specific regulatory filings and notifications

7.2 Investor Transparency

Our commitment to transparency includes:

• Regular Reporting: Quarterly investor reports with performance and portfolio updates
• Annual Audits: Independent audited financial statements by Big Four accounting firms
• Compliance Certifications: Regular compliance certifications and attestations
• Open Communication: Responsive investor relations and compliance inquiries

8. ESG and Sustainable Investing

8.1 Environmental, Social, and Governance Integration

Our ESG framework includes:

• Environmental Impact: Assessment of environmental impact of copyright assets and operations
• Social Responsibility: Fair compensation practices and support for artist communities
• Governance Standards: High standards of corporate governance and stakeholder engagement
• Sustainable Practices: Integration of sustainability considerations in investment decisions

9. Training and Culture

9.1 Compliance Training

Comprehensive training programs cover:

• Regular Training: Mandatory compliance training for all employees
• Industry Updates: Ongoing education on regulatory changes and best practices
• Professional Development: Support for relevant professional certifications
• Ethics Training: Code of conduct and ethical behavior training

9.2 Compliance Culture

Building a strong compliance culture through:

• Tone at the Top: Leadership commitment to compliance and ethical behavior
• Clear Accountability: Well-defined roles and responsibilities for compliance
• Open Communication: Whistleblower protections and reporting mechanisms
• Continuous Improvement: Regular review and enhancement of compliance programs

10. Regulatory Engagement

10.1 Regulatory Relationships

We maintain constructive relationships with regulators:

• Proactive Communication: Regular dialogue with regulatory authorities
• Industry Participation: Active participation in industry associations and working groups
• Regulatory Feedback: Contribution to regulatory consultations and policy development
• Best Practice Sharing: Collaboration on industry best practices and standards

11. Contact Information

For compliance-related questions or concerns, contact our Compliance Department:

Authenta Invest - Chief Compliance Officer
Email: [email protected]