AML compliance for micro-cap forex prop firms
I've been looking into starting a small forex prop firm, very lean, maybe just me and a few friends initially, focusing on a specific strategy. We'd be pooling capital but not taking outside investors right away. My main hurdle right now is understanding the extent of AML/KYC obligations for such a small entity, especially if we're operating across borders (say, US-based but trading EURUSD primarily). Do the full-blown AML programs apply immediately, or are there scaled requirements for micro-cap, internal-capital firms before hitting certain AUM or client thresholds? It's tough finding clear guidance for a setup this small without being advised to just go full institutional from day one, which isn't feasible.