AML Compliance Solutions for Capital Markets Firms
Protecting the Integrity of Registered Investment Advisers
The Financial Crimes Enforcement
Network (FinCEN), a bureau of the
U.S. Department of the Treasury,
recently proposed a rule requiring
certain investment advisers to establish
anti-money laundering (AML) programs
and adhere to reporting requirements
based on Bank Secrecy Act (BSA)
regulations. Affected advisers include
those registered with the U.S. Securities
and Exchange Commission, including
those serving certain hedge funds,
private equity funds, and other private
funds. FinCEN also proposed to include
investment advisers in the general
definition of “financial institution” and
require filing of Currency Transaction
Reports (CTRs) and Suspicious Activity
Reports (SARs). The rule would also
enforce recordkeeping requirements
related to the transmittal of funds.
The proposed AML rule seeks to
address potential money laundering
vulnerabilities in the U.S. financial system
while aligning investment advisers to
the standard of compliance required
of banking, broker-dealer, mutual
fund, and insurance organizations.
Look, Identify, and Prepare
At a minimum, affected firms should
examine their AML programs to
confirm the presence of elements
required to comply with BSA, AML,
and Office of Foreign Assets Control
(OFAC) regulations, including:
1. Establishing written, board/
management-approved
policies and procedures
2. Designating a qualified compliance
officer to oversee the program
3. Providing ongoing training
4. Conducting regular independent audits
The Crowe Horwath LLP team of AML
professionals can help you assess
your current program, capabilities,
processes, and controls. Using our deep
specialization and knowledge of AML
requirements, we can offer you tools to
help you prepare for new supervisory
requirements and expectations.
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Crucial Questions You
Need to Answer
■■ Are you familiar with the
proposed rule for investment
adviser AML compliance?
■■ Have you defined your risk
appetite and tolerances and
risk-assessed your clients and
counterparties?
■■ Does your program screen for
clients, counterparties, countries,
and beneficiaries using current,
applicable sanctions lists?
■■ Do you currently monitor
higher-risk transactions, such as
redemptions?
■■ Have your board and
management received
comprehensive AML training?
■■ When was your last independent
AML audit performed?
Has management fully
responded to prior audit and
examination results?
■■ How ready is your program for
increased scrutiny? Can you
demonstrate a compelling case
in line with leading industry
practices and supervisory
expectations?
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Focus on Effective AML Compliance
Crowe has built a strong reputation for assisting firms working toward the rewards
of effective AML compliance and risk management. We view AML compliance as
a continual process of vigilance grounded in a proactive approach designed to
raise red flags when significant changes, variances, and contradictions occur.
Changing requirements demand a clear plan for enhanced compliance. Crowe
specialists can help you create a risk-based AML program tailored to your specific
needs in today’s complex environment.
Our specialists use a cost-effective, industry-focused, and technology-enabled
methodology to guide efforts and manage requirements. The goal is to develop a
plan for enhancing AML programs that can help your organization reach higher levels
of maturity in corporate governance, risk assessment, risk-based customer due
diligence, suspicious activity monitoring, investigations, reporting, and other areas.
Corporate Governance/Enterprise Risk Management
Enterprisewide Compliance Risk Assessment
AML Risk Assessment
Risk Profile
Staffing/Training
Policies
Written Procedures
Risk-Based
Customer
Due Diligence
Suspicious Activity
Monitoring
Single Customer View
& Data Analytics
Data and Document Management
Model Validation and Calibration
Investigations
and Reporting
Model Risk Management and Model Governance
Model Development, Implementation and Use
Program, Project and Regulatory Relationship Management
Effective Internal Controls
Monitoring/Self-Testing
Independent Audit
The Crowe Closed Loop Anti-Money Laundering Program (Crowe CLAMP) is based on more than a
decade of experience assisting organizations of all sizes develop real-world, proven best practices.
Choose Comprehensive Services
Crowe AML compliance and audit services include independent BSA/AML audits.
We can also assist with reviewing and developing policies and procedures and training
programs and facilitate risk assessments of geographic, product and service, and
client and investor risks.
Although not yet mandated under the proposed rule, integrating robust customer
due diligence (CDD), know your customer (KYC), and Customer Identification
Program (CIP) elements into your AML program provides an effective mechanism for
proactively aligning your AML program to industry trends and managing customer
risk. CDD programs demonstrate robust due diligence and sanctions screening
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processes required for every client
and investor, as well as the enhanced
due diligence processes required
for clients and investors posing
higher risks. Crowe professionals
are experienced in assessing and
remediating CDD deficiencies. We
can also assist in the development
of ongoing monitoring and screening
programs to help provide lasting value.
Suspicious activity, regardless of its
origin, requires detailed investigation
and documentation by qualified
individuals. Crowe AML specialists can
help develop monitoring, enhanced due
diligence, and sanctions alert review
programs. We can also assist with
the optimization of AML compliance
operations teams and investigation units.
Comprehensive Crowe services also
offer ongoing support in the design,
development, and implementation
of transaction monitoring
systems, including assessment,
implementation, enhancement,
calibration, and validation services.
Select a Valued Resource
With more than 50 years of experience,
Crowe is a leading provider of
professional services to the financial
services industry. Asset managers,
broker-dealers, insurance providers,
and other firms can choose from our
full range of AML compliance services
to help implement effective controls,
streamline operations, and manage risk.
Let us help you navigate the regulatory
expectations set in place by BSA, AML,
OFAC, and global sanctions laws.
For more information on our
AML services for investment
advisory firms, please contact:
Vicky Ludema
+1 800 599 2304
[email protected]
www.crowehorwath.com
In accordance with applicable professional standards, some firm services may not be available to attest clients.
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