Investor Onboarding

FundAdmin AI's Investor Compliance & Onboarding category provides six skills that implement the full subscription pipeline -- from initial investor classification through AML screening, KYC tracking, and final accept/reject decision. The pipeline ensures that every investor is properly qualified, screened, and documented before capital is accepted.

The Subscription Pipeline

Six skills execute in sequence for each new investor:

investor-classify → suitability-check → fatca-crs-classify → aml-screen → kyc-tracker → subscription-process

Step	Skill	What It Does
1	`investor-classify`	Identify investor type from 10 categories
2	`suitability-check`	Verify qualification threshold (AI / QC / QP)
3	`fatca-crs-classify`	Determine tax forms required and CRS reporting obligations
4	`aml-screen`	Screen investor and beneficial owners against OFAC and PEP lists
5	`kyc-tracker`	Record KYC documents collected, expiration dates, refresh schedule
6	`subscription-process`	Orchestrate all five steps and produce pass/fail decision

The entire pipeline can be run as a single command via subscription-process, or each step can be run individually for partial processing or re-screening.

Step 1: investor-classify

bash

/fund investor-classify path/to/subscription-docs.pdf

Classifies the investor into one of 10 investor types based on the subscription documents, entity formation documents, and any provided certifications.

10 Investor Types

Type	Key Characteristics	Special Handling
U.S. Individual	Natural person, U.S. tax resident	W-9, basic KYC
U.S. Entity	LLC, LP, corporation, trust	EIN verification, beneficial ownership
Tax-Exempt	Endowment, foundation, DAF	Form 990 verification, UBTI analysis
Benefit Plan	ERISA plan, 401(k), IRA, governmental plan	ERISA 25% test contribution monitoring
Government	Sovereign wealth fund, public pension	Enhanced PEP screening, pay-to-play review
Non-U.S. Individual	Foreign natural person	W-8BEN, CRS self-certification
Non-U.S. Entity	Foreign corporation, foreign LP	W-8BEN-E, FATCA classification, CRS
Financial Institution	Bank, broker-dealer, insurance company	FATCA FFI verification, enhanced due diligence
Fund-of-Funds	Other investment funds	Look-through analysis for beneficial ownership
Special	Feeder fund, SPV, blocker entity	Structure-specific analysis, upstream investor review

Classification output feeds directly into steps 2-5, setting the applicable qualification thresholds, form requirements, and screening depth for each subsequent step.

Step 2: suitability-check

bash

/fund suitability-check path/to/subscription-docs.pdf

Verifies that the investor meets the qualification threshold required by the fund's Reg D exemption structure.

Qualification Thresholds

Level	Natural Person	Entity	When Required
Accredited Investor	$1M net worth (excl. primary residence) or $200K/$300K income	$5M in assets	Section 3(c)(1) funds; Rule 506(b)
Qualified Client	$2.2M net worth or $1.1M AUM with adviser	$2.2M net worth	Performance fee eligibility
Qualified Purchaser	$5M in investments	$25M in investments	Section 3(c)(7) funds

The skill reads the fund's exemption structure from the LPA review (if available) and applies the correct threshold automatically. If no prior LPA review exists, it defaults to the most restrictive threshold (QP) and flags the assumption for confirmation.

Output: PASS / FAIL with the specific threshold applied and the investor's self-certified financial information extracted from the subscription document.

Step 3: fatca-crs-classify

bash

/fund fatca-crs-classify path/to/subscription-docs.pdf

Determines the investor's FATCA entity classification and CRS reporting obligations, then identifies which W-forms must be collected and validated.

FATCA Form Requirements by Investor Type

Investor Type	Form Required	Notes
U.S. Individual	W-9	TIN certification
U.S. Entity	W-9	EIN certification
Non-U.S. Individual	W-8BEN	Foreign status, treaty claims
Non-U.S. Entity (NFFE)	W-8BEN-E	FATCA status, substantial U.S. owners
Non-U.S. Entity (FFI)	W-8BEN-E or W-8IMY	GIIN required for participating FFIs
Non-U.S. Intermediary	W-8IMY	Withholding statement required

The skill validates that the collected W-form is consistent with the investor's stated classification. A non-U.S. entity claiming deemed-compliant FFI status must provide a GIIN; if none is provided, the skill flags the inconsistency.

Output: Form requirements list, CRS reporting jurisdictions, consistency check result (PASS / WARNING / FAIL).

Step 4: aml-screen

bash

/fund aml-screen path/to/subscription-docs.pdf

Screens the investor and all beneficial owners (individuals owning 25%+ of the investing entity) against:

OFAC SDN list (Specially Designated Nationals and Blocked Persons)
OFAC consolidated sanctions lists (sector, country, and program-based)
FinCEN advisories (geographic targeting orders, 314(a) requests)
PEP databases (Politically Exposed Persons and their immediate family members)
Adverse media (negative news screening for AML red flags)

Screening Output

Each screened party receives one of four statuses:

Status	Meaning	Required Action
Clear	No matches found	Proceed to KYC
Possible Match	Partial name or identifier overlap	Manual review required
Match	High-confidence match against sanctions list	Do not accept; file SAR if required
PEP	Politically exposed person identified	Enhanced due diligence required

A Match result on any party (investor or beneficial owner) is an automatic FAIL for the subscription. The subscription is placed in the "Fraud Review" column of the Investor Onboarding Kanban board and flagged for escalation.

Step 5: kyc-tracker

bash

/fund kyc-tracker --investor "Investor Name"

Creates and maintains a KYC record for the investor in the Obsidian vault. The record tracks:

Documents collected (government ID, certificate of formation, operating agreement, etc.)
Collection date for each document
Document expiration dates
KYC review date and reviewer
Risk classification (Low / Medium / High)
Next scheduled refresh date

KYC Refresh Cycles

KYC is not a one-time event. Investor circumstances change, and regulations require periodic re-verification. Standard refresh cycles by risk level:

Risk Level	Triggers	Refresh Frequency
Low	Standard investors, no adverse flags	Every 3 years
Medium	Complex structures, non-U.S. entities	Every 2 years
High	PEPs, high-risk jurisdictions, prior flags	Annually

The KYC Tracker writes expiration dates to the investor's vault note. The vault's KYC Status dashboard queries these dates and surfaces investors with KYC expiring within 90 days in the Action Items board, ensuring no investor's KYC lapses unnoticed.

Step 6: subscription-process

bash

/fund subscription-process path/to/subscription-docs.pdf

The subscription-process skill orchestrates all five upstream steps in a single command. It:

Runs all five skills in sequence on the provided subscription document
Aggregates results into a consolidated subscriber report
Issues a pass/fail decision with a list of any outstanding items
Writes the investor record to the Obsidian vault
Adds a card to the Investor Onboarding Kanban board reflecting the current status

Consolidated Subscriber Report

The report includes:

Section	Contents
Investor Summary	Name, type classification, qualification level
Suitability	Threshold applied, investor's self-certified financials, PASS/FAIL
FATCA/CRS	Forms required, forms collected, consistency check
AML Screening	Parties screened, results, any flags
KYC Status	Documents required, documents collected, outstanding items
Decision	ACCEPT / CONDITIONAL ACCEPT / REJECT with specific items to resolve

A CONDITIONAL ACCEPT means the investor has passed suitability and AML screening but has outstanding KYC documents. The investor can be provisionally accepted with a document collection deadline.

A REJECT means the investor failed suitability, has a sanctions match, or has unresolvable compliance gaps.