AML (Anti‑Money Laundering) Leader

Title:
AML (Anti‑Money Laundering) Leader / AML Officer (VP Level)

Engagement Type:
Contract

Bill Rate:
$50-60/hr.

Experience Level:
5–8 years
Role Overview
We are seeking an experienced AML Leader / AML Officer to design, implement, and oversee a comprehensive, risk‑based Anti‑Money Laundering and Counter‑Financing of Terrorism (AML/CFT) program for private fund structures, including private equity, hedge funds, and venture capital. This VP‑level role is critical as new FinCEN AML/CFT rules effective January 1, 2026, expand AML obligations for Registered Investment Advisers (RIAs) and Exempt Reporting Advisers (ERAs).
The AML Leader will serve as the firm’s designated AML Officer, maintaining independence and direct access to senior leadership while ensuring regulatory compliance and program effectiveness.
Key Responsibilities
AML Program Design and Oversight
• Develop, implement, and maintain written AML policies, procedures, and internal controls aligned with the firm’s risk profile
• Ensure the AML program meets all applicable regulatory requirements under BSA, USA PATRIOT Act, and new FinCEN investment adviser rules
Investor Due Diligence (KYC/CDD)
• Oversee Know Your Customer (KYC) and Customer Due Diligence (CDD) processes for new and existing investors
• Verify beneficial ownership for individuals or entities with 25 percent or greater ownership
• Review enhanced due diligence for higher‑risk investors
Risk Assessment and Monitoring
• Identify, assess, and monitor AML risk across investor base and fund activity
• Manage reviews involving Politically Exposed Persons (PEPs), complex ownership structures, and non‑transparent sources of wealth
• Monitor capital calls, subscriptions, redemptions, and distributions for unusual or suspicious activity
Suspicious Activity Reporting (SARs)
• Investigate AML red flags and potential suspicious activity
• Prepare and file Suspicious Activity Reports (SARs) in accordance with regulatory requirements
Independent Testing and Audits
• Coordinate annual independent AML testing or audits
• Address findings and ensure timely remediation of any identified gaps
Training and Awareness
• Develop and deliver AML training for internal teams, tailored to role and risk exposure
• Promote ongoing AML awareness across the organization
Regulatory and Stakeholder Liaison
• Serve as the primary point of contact for regulators, examiners, and, when required, law enforcement
• Partner with fund administrators and external service providers while retaining internal oversight and accountability
Qualifications and Requirements
• 5+ years of AML compliance, financial crime, or risk management experience within financial services
• Strong preference for experience in asset management, private equity, hedge funds, or alternative investments
• CAMS or similar certification strongly preferred (e.g., ICA, CRCM, Certified Risk Professional)
• In‑depth knowledge of BSA, USA PATRIOT Act, and post‑2026 AML/CFT rules for investment advisers
• Demonstrated ability to operate independently, influence senior stakeholders, and lead compliance initiatives
• Excellent analytical, written, and verbal communication skills
Additional Context
• This role requires sufficient authority and independence to implement and enforce the AML program
• While certain operational tasks may be outsourced, the AML Officer retains responsibility and oversight
• Particular focus will be placed on source of wealth/source of funds analysis and investor transaction monitoring
Equal Opportunity Employer/Veterans/Disabled
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The Company will consider qualified applicants with arrest and conviction records in accordance with federal, state, and local laws and/or security clearance requirements, including, as applicable:
• The California Fair Chance Act
• Los Angeles City Fair Chance Ordinance
• Los Angeles County Fair Chance Ordinance for Employers
• San Francisco Fair Chance Ordinance