AML compliance for private fund advisers
Registering with the SEC as an adviser to one or more private funds does not create a separate compliance track. FinCEN's AML rule reaches every SEC-registered investment adviser, fund managers included, and a fund's own administrator or subscription-document diligence is not a substitute.
The rule reaches the adviser, not just the fund
The four pillars, a written program, a designated compliance officer, staff training, and an independent test, attach to the registered adviser. Nothing in a fund's own subscription-agreement diligence, or an administrator's KYC process, changes what the adviser itself must maintain.
The reliance question FinCEN already answered
FinCEN considered letting advisers rely on diligence performed by another financial institution, service provider, or intermediary, and declined: "the adviser will remain responsible for overall compliance with these requirements" (89 FR 72156, p. 72188). A fund's outside administrator handling investor onboarding does not move that responsibility.
One deadline, four pillars, one fixed price
January 1, 2028, per FinCEN's postponement rule (91 FR 36). Praxtrust builds the written program and designation calibrated to a fund-adviser structure, then runs the annual independent test the rule requires, at a fixed price agreed before any work starts.