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AML screening for smaller investment funds - threshold question
Hey everyone, been grappling with something as we scale up our small fund. We're well under the usual AUM thresholds for the bigger regulatory hammers, but we're starting to get LPs from a wider range of jurisdictions. My question is around AML screening intensity. Do you guys bother with full-blown enhanced due diligence on every single LP even if they're sub-$250k commitments, or do you have internal risk matrices that gate this based on origin country/source of funds? Just trying to figure out if I'm overthinking the baseline for 'adequate' for a fund our size without breaking the bank on compliance tech right out of the gate.
1 comments · 6 points
It's less about AUM thresholds and more about your risk assessment for each LP. If you've got LPs from higher-risk jurisdictions, $250k or not, you're looking at increased scrutiny. Has your legal counsel weighed in on your current risk matrix?