Policy Statement & Regulatory Framework
OTR Partners maintains a zero-tolerance policy toward money laundering, terrorist financing, proliferation financing, tax evasion, and sanctions evasion. Our global compliance framework adheres to the standards established by:
- The Financial Action Task Force (FATF) Recommendations;
- The British Virgin Islands Anti-Money Laundering Regulations and Anti-Money Laundering and Terrorist Financing Code of Practice;
- The US Bank Secrecy Act (BSA) and USA PATRIOT Act (FinCEN);
- The Luxembourg Law of 12 November 2004 on the fight against money laundering and terrorist financing (supervised by the CSSF);
- The Act on Reporting and Using Specified Financial Transaction Information of the Republic of Korea (KoFIU).
Customer Due Diligence (CDD) & Ultimate Beneficial Ownership (UBO)
Prior to admitting any Limited Partner ("LP"), co-investor, or commercial counterparty (including intellectual property sellers and music catalog rightsholders), OTR Partners conducts rigorous risk-based due diligence:
- Identity Verification: Verification of natural persons via government-issued passports and proof of residential address.
- Corporate Verification: Collection of Certificates of Incorporation, Articles/Memorandum of Association, Partnership Agreements, and Registers of Directors and Members.
- UBO Identification: Mandatory identification and verification of all natural persons who ultimately own or control 10% or more (or 25% where standard risk applies) of a legal entity, or who exercise ultimate effective control over a trust, foundation, or partnership.
Enhanced Due Diligence (EDD) & Politically Exposed Persons (PEPs)
Enhanced Due Diligence is automatically triggered for prospective investors or counterparties connected to high-risk jurisdictions, complex offshore trust structures, or Politically Exposed Persons (PEPs), their immediate family members, and close associates. Admission of any PEP requires explicit written approval from the Chief Compliance Officer (CCO) and the General Partner.
Verification of Source of Wealth (SoW) & Source of Funds (SoF)
All prospective LPs must provide verifiable documentation substantiating both the origin of their overall net worth (Source of Wealth) and the specific origin of the capital committed to the Fund (Source of Funds). Acceptable transfers must originate solely from a bank account held in the exact legal name of the subscribing LP at a regulated financial institution in an approved FATF-compliant jurisdiction. Third-party payments, cash, and anonymous crypto-asset transfers are strictly prohibited.
Sanctions Screening & Ongoing Monitoring
All investors and transaction counterparties are screened continuously against global sanctions lists, including OFAC (US), UN Security Council, EU Consolidated Sanctions, HM Treasury (UK), and BVI/Korean regulatory watchlists.