MLRO Professional Service Offering

 Designation and Leadership by an Experienced MLRO:

• Dedicated MLRO Placement: Assigning an experienced MLRO to oversee all aspects of the fund’s AML compliance, ensuring adherence to regulatory requirements specific to alternative investment funds.
• Strategic AML Oversight: Providing strategic leadership in developing and implementing the fund’s AML framework, aligned with the specific risks and operational nuances of alternative investments.
• Regulatory Liaison: Acting as the primary point of contact with regulatory bodies, handling all necessary AML filings and ensuring timely and accurate submission of Suspicious Activity Reports (SARs) and other compliance documents.
  
  Customized AML Framework for Alternative Funds: 

• Policy and Procedure Development: Creating or refining AML policies and procedures tailored to the fund’s structure, investment strategies, and risk profile, ensuring compliance with local and international AML regulations.
• Risk-Based Approach Implementation: Developing and implementing a risk-based approach to AML, focusing on the unique risks posed by the fund’s investors, transactions, and geographic exposure.
• KYC and CDD Processes: Overseeing robust Know Your Customer (KYC) and Customer Due Diligence (CDD) processes designed for high-net-worth and institutional investors typically involved in alternative funds.
  
  Enhanced Transaction and Investor Monitoring: 

• Ongoing Investor Screening: Conducting thorough screening of investors, including beneficial owners, to detect and mitigate money laundering risks, particularly focusing on complex ownership structures and cross-border investments.
• Transaction Monitoring: Implementing advanced monitoring systems to scrutinize fund transactions for unusual activity, ensuring compliance with AML regulations and identifying potential risks early.
• Enhanced Due Diligence (EDD): Performing Enhanced Due Diligence on high-risk investors, transactions, and jurisdictions, particularly in cases involving politically exposed persons (PEPs) or high-risk countries.
  
  Internal Controls and Compliance Program Management: 

• Compliance Program Development: Leading the creation and management of a comprehensive AML compliance program, including internal controls and procedures specific to alternative investment funds.
• Regular Audits and Reviews: Conducting regular internal audits of the AML framework to ensure effectiveness, identify gaps, and implement improvements as needed.
• Crisis Management: Providing immediate response and guidance in the event of AML-related incidents, including managing communication with regulators and other stakeholders.
  
  AML Training and Education:

• Specialized Training for Staff: Designing and delivering training programs for fund managers, compliance teams, and other personnel on AML risks and responsibilities specific to alternative funds.
• Board and Senior Management Training: Offering tailored training sessions for the fund’s board and senior management, focusing on governance, oversight, and strategic AML management.
  
  AML Risk Assessment and Mitigation Strategies: 

• Fund-Specific Risk Assessments: Conducting detailed AML risk assessments tailored to the fund’s investment strategies, investor base, and geographic exposure.
• Mitigation Planning: Developing and implementing strategies to mitigate identified AML risks, including enhancements to policies, procedures, and transaction monitoring practices.
  
  Regulatory Reporting and Documentation: 

• SARs and Mandatory Reporting: Ensuring the timely and accurate submission of Suspicious Activity Reports (SARs) and other required AML filings to relevant regulatory bodies.
• Comprehensive Record-Keeping: Maintaining detailed records of all AML-related activities, including investor due diligence, transaction monitoring, and regulatory communications, in compliance with legal requirements.
  
  Advisory and Consultation Services: 

• Ongoing AML Advisory: Providing continuous consultation and advice on AML matters, including updates on regulatory changes, emerging risks, and industry best practices.
• Policy and Procedure Review: Regularly reviewing and updating the fund’s AML policies and procedures to ensure they remain effective and aligned with the latest regulatory requirements.
• Regulatory Audit Preparation: Assisting in the preparation for regulatory audits and examinations, including pre-audit reviews and post-audit remediation efforts.

Benefits of the Service: 

• Expert Compliance Leadership: Leveraging the expertise of a seasoned MLRO to ensure your fund’s AML framework is robust, effective, and compliant with all relevant regulations.
• Tailored Solutions: Providing AML solutions specifically designed to address the unique challenges and risks associated with alternative investment funds.
• Regulatory Assurance: Reducing the risk of regulatory breaches and penalties by ensuring comprehensive compliance with AML laws and regulations.
• Investor Confidence: Enhancing investor confidence by demonstrating a strong commitment to AML compliance and risk management.

Who Can Benefit:

• Hedge funds, private equity funds, venture capital funds, and real estate investment funds.
• Funds operating in multiple jurisdictions with complex regulatory requirements.
• Alternative investment funds with a diverse and high-net-worth investor base.
• Fund managers and administrators seeking to strengthen their AML compliance framework.

This service is designed to ensure that alternative investment funds meet their AML obligations effectively, mitigate risks, and maintain strong relationships with regulators and investors.

• Business Risk Assessment which provides a summary of our current assessment of the firm’s ML/TF risks.
• Provision of MLRO
• AML/CFT expertise re regulatory requirements and market practice
• Sanction Screening data for country risks, PEP exposures, UBO’s
• A documented process to follow in the event we become aware of suspicious activities
• A training plan for the board and staff and evidencing of such
• Outsourced investor ID and verification, customer onboarding
• Design AML policies, procedures, controls, risk mitigation plans
• Review onboarding procedures and records