How Fund Managers Can Navigate U.S. and Cayman Islands AML Requirements (Part Two of Two)

A recent Hedge Fund Law Report program delved into best practices for anti-money laundering (AML) compliance by private fund managers. This second article in our two-part series explores common AML controls adopted by fund managers, ways the SEC reviews an adviser’s AML program, day-to-day challenges that fund managers face when implementing their AML controls and best practices when delegating AML responsibilities to a fund administrator. The first article reviewed the current U.S. AML requirements and provided an update on the recently amended Cayman Islands AML regime. The program was moderated by Kara Bingham, Senior Editor of the Hedge Fund Law Report, and featured Sarah Curran, director at Promontory Financial Group; Lucy Frew, partner at Walkers; and Seetha Ramachandran, partner at Proskauer. For a look at AML regulations in the U.K., see “Preparing for Brexit a Key FCA Priority for 2018/2019” (May 31, 2018); and “FCA Fines Deutsche Bank £163 Million for Lax AML Controls, Warns Other Firms to Review AML Procedures” (Feb. 9, 2017).

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