The AML regulations for investment advisers and pooled funds highlight several key points. The sheer size of the pooled funds sector now makes it vulnerable to illicit actors. The finalized rule, dated August 28, mandates that investment advisers comply by January 1, 2026. Investment advisers located outside the U.S. will also be covered unless exempted. Advisers will have the option to delegate or rely on third parties for certain requirements. Institutions and firms must begin considering the implications as soon as possible. Effective compliance and risk management will depend significantly on implementing the right mix of technology. Investment advisers registered with or reporting to the SEC will soon face comprehensive AML and customer identification requirements, including the filing of SARs. The time is now for institutions and firms to consider these implications and prepare their programs. Contact us for more information.

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