COMPLIANCE

Compliance and counterparty verification

How the Manager verifies investors and counterparties, and what banks and compliance teams can request when reviewing the Fund.

Regulatory status

Lava Invest Management OÜ is entered in the list of small fund managers without activity licence (Tegevusloata väikefondi valitsejad) maintained by the Estonian Financial Supervision Authority.

The Financial Supervision Authority supervises small fund managers only for compliance with the registration obligation and the submission of information.

Finantsinspektsioon

Anti-money laundering and counter-terrorist financing

The Manager maintains internal control procedures designed to prevent the Fund or any portfolio company from being involved in money laundering, tax evasion, fraud or corrupt practices. These include:

risk-based customer due diligence for investors and transaction counterparties;
identification and verification of ultimate beneficial owners;
verification of the source of funds and, where required, the source of wealth;
ongoing monitoring of business relationships;
withholding distributions from partners who do not meet anti-money laundering requirements;
reporting to the Financial Intelligence Unit where required by law.

Conflicts of interest

Partners with a potential or actual conflict of interest are excluded from voting on the matter concerned.

The Manager takes investment decisions independently of limited partners and third parties.

On liquidation, any sale of Fund assets to the Manager must be made at the average market price, confirmed in advance by the auditor.

Confidentiality and data protection

The terms of the Fund and information about its partners are kept confidential, except where disclosure is required by law or regulation. Personal data is processed in accordance with the Privacy Policy.