AML compliance for small investment firms – how granular does it get?
Starting to get my head around AML requirements, and while the big picture makes sense, I'm a bit lost on the practical application for smaller shops. For a firm handling, say, under $50M AUM and not dealing with super-high-risk clients, how deep do you really need to go on enhanced due diligence for every new account? Is there a common sense threshold, or is it a 'paint by numbers' approach regardless of scale?