Hedge Fund AML

All United States-based fund managers must comply with the USA Patriot Act of 2001 and the myriad of regulations promulgated by the Department of Treasury through the Office of Foreign Asset Control ("OFAC") and the Financial Crimes Enforcement Network ("FinCEN"). Given the pseudo-anonymous nature of cryptocurrency, there is a growing enforcement trend towards failures to actively engage and enforce strict Anti-Money Laundering policies and procedures. This is especially relevant in situations where a hedge fund accepts bitcoin or other cryptocurrency in lieu of fiat currency as an investment.

A hedge fund's AML obligations include not only verifying the identity of the source of capital but also the beneficial owner of contributed assets. This can be particularly challenging when it comes to virtual currency as both the source of capital and beneficial owner can easily be masked. The experts at Wabash Advisors can assist you in designing an effective, compliant AML and KYC program