U.S. hedge funds, private equity funds and venture capital funds, and their U.S. general partners, sponsors and managers are not directly subject to the Bank Secrecy Act of 1970 and its amendments.

However, advisers are encouraged to implement a risk-based anti-money laundering, or AML, compliance program similar to those implemented by financial institutions and with whom the advisers and private funds engage with on a regular basis for multiple transactions — e.g., custody, loan, trading, banking and other activities.

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