Effective Date: September 1, 2026

1. Introduction

Vestra ("Vestra," "we," "our," or "us") is committed to maintaining a secure, transparent, and compliant investment platform. As a digital real estate investment platform, we recognize our responsibility to prevent our Platform from being used for money laundering, terrorist financing, fraud, sanctions evasion, identity theft, or any other financial crime.

This Know Your Customer ("KYC") and Anti-Money Laundering ("AML") Policy explains the measures Vestra takes to verify customer identities, monitor transactions, manage financial crime risks, and comply with applicable laws and industry best practices.

This Policy should be read together with our:

• Terms of Service

• Privacy Policy

• Risk Disclosure Statement

• Investment Disclaimer

2. Purpose

The purpose of this Policy is to:

• Verify the identity of every customer before providing investment services;

• Prevent money laundering and terrorist financing;

• Detect and prevent fraud and identity theft;

• Comply with applicable laws and regulatory obligations;

• Protect investors and the integrity of the Platform;

• Reduce financial crime risks;

• Support a safe and trustworthy investment environment.

3. Scope

This Policy applies to:

• All individuals creating an account with Vestra;

• Existing users of the Platform;

• Investors purchasing investment opportunities;

• Users participating in secondary marketplace transactions where available;

• Referral participants where identity verification is required;

• Any individual or entity using Vestra's financial services.

Vestra may apply additional verification requirements depending on the nature of a user's activities or regulatory obligations.

4. Customer Identification Program (KYC)

Before providing access to investment services, Vestra may verify the identity of every user.

Information that may be requested includes:

• Full legal name;

• Date of birth;

• Residential address;

• Government-issued identification;

• Selfie or biometric verification where permitted by law;

• Proof of address;

• Nationality;

• Tax identification information where applicable;

• Source of funds information;

• Source of wealth information where required;

• Occupation or employment details where necessary.

Vestra may request additional documentation whenever required to complete verification or satisfy regulatory obligations.

5. Identity Verification

Identity verification may be completed using trusted third-party verification providers.

Verification methods may include:

• Government ID validation;

• Facial comparison technology;

• Document authenticity checks;

• Address verification;

• Database verification;

• Fraud detection tools;

• Liveness detection;

• Identity risk scoring.

Verification may occur:

• During account registration;

• Before making an investment;

• Before withdrawals;

• Before participating in secondary marketplace transactions;

• Whenever suspicious activity is identified;

• Periodically as part of ongoing compliance monitoring.

6. Risk-Based Approach

Vestra applies a risk-based approach to customer verification.

Certain users or transactions may require enhanced review based on factors such as:

• Geographic location;

• Transaction size;

• Investment activity;

• Payment method;

• Frequency of transactions;

• Source of funds;

• Regulatory requirements;

• Suspicious activity indicators.

Higher-risk accounts may be subject to Enhanced Due Diligence (EDD).

7. Enhanced Due Diligence (EDD)

Where appropriate, Vestra may perform Enhanced Due Diligence before allowing certain transactions.

EDD may include:

• Additional identity verification;

• Source of wealth verification;

• Source of funds documentation;

• Additional proof of address;

• Financial statements where appropriate;

• Manual compliance review;

• Senior management approval where required.

Enhanced Due Diligence may also apply to Politically Exposed Persons (PEPs), high-risk jurisdictions, or other higher-risk customers.

8. Sanctions Screening

Vestra may screen users against applicable sanctions and watchlists maintained by governmental or international authorities.

Screening may include:

• International sanctions lists;

• Office of Foreign Assets Control (OFAC) sanctions;

• Politically Exposed Person (PEP) databases;

• Adverse media screening;

• Law enforcement watchlists;

• Other compliance databases where appropriate.

Users appearing on applicable sanctions lists may be denied access to the Platform where required by law.

9. Transaction Monitoring

To protect the Platform and comply with legal obligations, Vestra monitors transactions for unusual or suspicious activity.

Monitoring may include:

• Large or unusual transactions;

• Rapid movement of funds;

• Multiple linked accounts;

• High-frequency transactions;

• Structuring or layering activity;

• Suspicious withdrawal requests;

• Inconsistent account behaviour;

• Geographic anomalies;

• Fraud indicators.

Monitoring may be performed using automated systems together with manual review where appropriate.

10. Source of Funds

Vestra may request information regarding the origin of funds used for investments.

Acceptable sources may include:

• Employment income;

• Business income;

• Investment income;

• Savings;

• Sale of assets;

• Inheritance;

• Gifts where legally documented;

• Other lawful sources.

Users may be required to provide supporting documentation.

11. Ongoing Customer Due Diligence

Customer verification does not end once an account is approved.

Vestra may periodically:

• Update customer information;

• Request renewed identification documents;

• Confirm addresses;

• Review transaction activity;

• Reassess customer risk;

• Conduct additional verification where necessary.

Users are responsible for ensuring that their information remains accurate and up to date.

12. Suspicious Activity

If Vestra detects activity that appears unusual, fraudulent, or inconsistent with a user's profile, we may:

• Request additional information;

• Delay transactions;

• Restrict account activity;

• Suspend withdrawals;

• Decline investments;

• Freeze accounts where legally required;

• Report suspicious activity to appropriate authorities where required by law.

Vestra is not required to notify users when reporting suspicious activity if prohibited by law.

13. Record Retention

Vestra maintains customer identification and compliance records for the period required under applicable laws and regulatory obligations.

Records may include:

• Identity verification documents;

• Transaction records;

• Compliance reviews;

• Risk assessments;

• Customer communications relating to compliance.

When retention periods expire, records will be securely deleted or destroyed unless continued retention is legally required.

14. User Responsibilities

By using the Platform, you agree to:

• Provide accurate and truthful information;

• Submit genuine identification documents;

• Keep your account information updated;

• Cooperate with verification requests;

• Promptly respond to compliance inquiries;

• Use only funds obtained from lawful sources;

• Comply with all applicable laws.

Providing false information or forged documentation may result in immediate account suspension or permanent termination.

15. Refusal or Suspension of Services

Vestra reserves the right to refuse, suspend, restrict, or terminate services where:

• Identity cannot be verified;

• Required documentation is not provided;

• Fraud is suspected;

• Money laundering concerns arise;

• Sanctions restrictions apply;

• Regulatory obligations require action;

• Continued access would expose Vestra or its users to unacceptable legal or financial risk.

Such actions may be taken without prior notice where required by law.

16. Regulatory Cooperation

Where required by applicable law, Vestra may cooperate with:

• Financial regulators;

• Law enforcement agencies;

• Tax authorities;

• Financial intelligence units;

• Courts;

• Government agencies.

This may include sharing information or reporting suspicious activity where legally required.

17. Policy Updates

Vestra may update this Policy from time to time to reflect changes in laws, regulatory expectations, financial crime risks, or business operations.

Material updates will be published on the Platform with a revised Effective Date.

Continued use of the Platform after the Effective Date constitutes acknowledgment of the updated Policy.

18. Contact Us

If you have questions regarding this KYC/AML Policy or our compliance procedures, please contact us through:

Email: support@vestraproperties.pro

Contact Form: Available through the Platform

Live Chat: Available through the Platform