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.
Elizabeth has spent more than 20 years tackling money laundering (ML) and financial crime. At SymphonyAI she drives the strategy and innovation that delivers transformational compliance solutions. Prior to SymphonyAI she worked within the U.S. intelligence and law enforcement communities. As a Senior Intelligence Analyst with the U.S. Department of the Treasury, she drove U.S. policy and enforcement actions and supported U.S. officials and policymakers, including at OFAC and FinCEN, on ML threats and sanctions initiatives. She also served as Treasury’s first Intelligence Liaison and Senior Advisor to DEA’s Special Operations Division, spearheading large-scale ML investigations and intelligence collection initiatives, training law enforcement agents and analysts, and promoting collaboration between Treasury and U.S. and foreign law enforcement. In the private sector, Elizabeth also worked within financial institutions and consulting managing investigations teams, developing risk management strategies for complex products and services, and designing institutional AML programs and controls. Elizabeth also teaches AML and sanctions courses at the university level.