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 Callan has spent her 20+ year career tackling money laundering and financial crime. At SymphonyAI she uses her deep domain expertise and knowledge of analytics to deliver transformational thought leadership, enhance our core products, and drive client-centric innovative solutions. Prior to SymphonyAI, Elizabeth worked within financial institutions and consulting, managing investigations teams, developing risk management strategies for complex products and services, and designing institutional AML programs. Elizabeth also spent over a decade in the U.S. intelligence and law enforcement communities, where she drove U.S. policy and enforcement actions and supported U.S. officials and policymakers on money laundering and financial crime threats. She has a master’s degree in economics and data analytics, holds ACAMS’ advanced certification in financial crimes investigations (CAMS-FCI), and teaches AML courses at the baccalaureate level.