Anti-Money Laundering

Advisers to a Private Funds (aka, Hedge Fund) are deemed to have custody over the assets therein. Consequently, your firm must comply with the requirements of the Bank Secrecy Act of 1970 and Section 352 of the USA PATRIOT Act, more commonly referred to as Anti-Money Laundering law.

Your firm must implement and maintain an anti-money laundering (AML) program, that:

• Possesses a system of internal controls to prevent and detect money laundering
• Designates a responsible party (i.e., the CCO)
• Provides for on-going employee training
• Contains an independent audit function to test the effectiveness of program
• Monitors clients, investors and customers

TurboCompliance^® Anti-Money Laundering module installs a comprehensive, well-organized internal control structure around the entire client intake and management process in order to automate each aspect of your firm’s AML procedures.

The Bank Secrecy Act and “Know Your Customer” Rules (KYC)

TurboCompliance, via the TurboCompliance client extranet, automates the work-flow of gathering prospective investor information. Therefore, as a prospective client completes the requisite forms on the extranet, TurboCompliance ensures that they provide each piece of information your firm requires under your KYC procedures.

The PATRIOT Act and the OFAC SDN List Monitoring Rules

TurboCompliance automatically monitors and screens each new and existing client against the OFAC SDN list as scheduled by the CCO. More importantly, your firm can maintain multiple lists (from the FBI, Interpol, etc.,) within TurboCompliance, if desired.

Please request a TurboDoc Share Account to obtain a thorough discussion of how we work in concert with your CCO, law firm and CPA to build a version of TurboCompliance which delivers an absolute culture of compliance.

Since this section provides sample compliance procedure language, you must register for a TurboDoc Share Account in order to obtain access; please click here to request access.

In this section we provide a compliance practice guide which addresses:

• Section 352 of the PATRIOT Act, and the Office of Foreign Asset Control’s required Specially Designated Nationals List, aka OFAC SDN list
• The Bank Secrecy Act of 1970, and the “Know Your Customer” Requirements
• Anti-Money Laundering Audits
• Money laundering controls
• Identity procedures
• Prohibited transactions
• FATF countries
• Suspicious activities
• FinCEN