AML for small fund managers: practical scope?
Been diving into AML requirements, and while the big picture is clear for major institutions, I'm trying to get a handle on the practical scope for smaller, say, sub-$50M AUM fund managers. We're talking limited partners, often known to us. Are folks in that situation typically looking at full-blown dedicated AML officers, or does it usually get folded into a broader compliance role, maybe with outsourced support for the heavy lifting? Just trying to gauge what's realistic without going overboard, or worse, underboard.