การปฏิบัติตามกฎ AML สำหรับบริษัทลงทุนขนาดเล็ก – ต้องละเอียดแค่ไหน?

That's a very practical question. While the size of the firm doesn't necessarily reduce the regulatory obligations, the risk profile of your client base (HNWI/family offices) will heavily influence the CDD/EDD scope. It's often more about having a robust, documented risk-based approach rather than scrutinizing every single transaction, especially for routine ones from known, verified clients.

For smaller firms, the key is often a robust risk-based approach tailored to your client base. You won't have the same resources as a bulge bracket, but demonstrating you've identified and mitigated your specific risks is crucial, especially with HNWI and family offices.

Even for smaller firms, regulators expect a robust approach. It's less about transaction volume and more about the risk profile of the client and the nature of the assets. You still need to demonstrate you've done your due diligence, often to the same standard, just on a smaller scale.