While the rules don’t explicitly apply to registered investment advisers, advisers that manage mutual funds may be tasked with helping to ensure their mutual fund shareholders are compliant with the rules. The rules principally focus on the identification and verification of the beneficial owners and controllers of legal entities. Up to now, AML regulations have not specifically required identification of these individuals by investment companies and fund intermediaries. The new rules also outline the requirement for risk-based procedures for conducting ongoing AML due diligence and development of a customer risk profile.
For more information, please contact one of the authors listed below or the Drinker Biddle Investment Management Group lawyer with whom you regularly work.