A Practical Approach to Implementing an AML Compliance Program

A Practical Approach to Implementing an AML Compliance Program


AML (Anti Money Laundering) has become a prominent issue for private funds. As Louis Bruno, Principal at EisnerAmper’s Compliance and Regulatory Services, prepares to address the issue at The Global Alternative Investment Management Operations (GAIM Ops West Coast) Summit, we discussed a few key points with him in advance…

Why has AML become a prominent issue for private funds?

The Financial Crimes Enforcement Network’s (“FinCEN’s”) proposed rule requiring registered investment advisers to adopt AML programs will impose greater challenges for private fund managers to meet additional regulatory requirements, often with greater cost constraints and fewer resources.  However, there is a practical and effective way for fund managers to meet these obligations.

What issues should fund managers consider with respect to AML?

All AML programs should contain fundamental elements, such as maintaining policies and procedures and monitoring for suspicious activities.  But private fund managers should understand that their AML program should be tailored to the risks inherent in their organization, which often involve politically exposed persons amongst their investor base.


How should fund managers handle outsourcing of AML duties?

We find that many fund managers outsource part or all of their AML programs to third parties, usually their fund administrators.  That’s OK, but fund managers still retain the responsibility over the AML program and must perform adequate due diligence on the fund administrator’s AML program.  Regulators will expect as much.


This will be explored further at GAIM Ops West Coast on October 24-26, 2016 at Ritz Carlton, Rancho Mirage, CA, where Louis Bruno and Keith Miller, also from EisnerAmper LLP, will be participating in the presentation: “A Practical Approach to Implementing an AML Compliance Program for Asset Managers”. For more information about the agenda and event, please click here.

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