Section 352 of the Patriot Act requires all financial institutions, including hedge funds and other investment companies, to establish anti-money laundering (AML) programs which must include, at minimum, developing internal policies, procedures and controls; designating a compliance officer; establishing an ongoing employee training program, and establishing independent audit functions to test programs and obtaining outside, independent legal counsel.  At minimum, investment funds must revise their procedures to be responsive to the requests of broker-dealers.

Our firm will provide outside, independent legal counsel to help you analyze AML requirements for hedge funds; what do the regulations require and how do you implement them. It will counsel investment funds on their statutory reporting requirements and how they may be at risk for being used to launder money. It will develop strategies to comply with “Know your Investor” and Due Diligence and Enhanced Due Diligence requirements. It will develop policies to determine investor identification policies and procedures and which “cash” reporting requirements apply. It will develop procedures to detect, respond to and report suspicious activity. It will assist your institution in developing effective training of employees on AML controls.