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Anti-Money Laundering Procedures

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  • dbrown8289@aol.com
    Fundlaw Group, Our firm, Self Audit, Inc. has created model anti-money laundering procedures for mutual fund companies. These model procedures delegate the
    Message 1 of 3 , Apr 1, 2002
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      Fundlaw Group,

      Our firm, Self Audit, Inc. has created model anti-money laundering procedures
      for mutual fund companies. These model procedures delegate the
      responsibility of having an AML Program to the Investment Adviser. We are in
      the process of completing an Investment Advisers AML Program Kit. This kit
      contains an employee training program (powerpoint slides), due diligence
      information on "covered service providers" and other relevant information.
      Any firm interested in obtaining this kit should register at our website (via
      the free download) at www.selfauditor.com. We are working feverishly to have
      this kit available by April 4th.

      In creating this program we reviewed pre-existing AML Procedures, the GAO
      Report on Anti-Money Laundering, ICI information, other similar procedures
      and various other sources. Although there is not much guidance on the
      requirements of a program, this program creates an initial structure whereby
      an investment adviser can become informed about anti-money laundering
      requirements.

      Regards,
      Debra Brown
      Self Audit, Inc.
      20 Oak Street
      Beverly Farms, MA 01915
      978.921.6688
      dbrown@...

      Please feel free to contact me directly at 978.921.6688. Have a great day!


      [Non-text portions of this message have been removed]
    • Vicki Hulick
      Debra, Interesting approach since investment advisers are not currently required to have such a program under the current definitions! However, I will note
      Message 2 of 3 , Apr 1, 2002
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        Debra,

        Interesting approach since investment advisers are not currently required to
        have such a program under the current definitions!

        However, I will note that we are developing procedures for our mutual funds
        that can be used broadly by our adviser, as well as by our affiliated
        limited purpose broker-dealer (underwriter to our institutional mutual funds
        only). I suspect other advisers with funds and/or affiliated broker-dealers
        are doing the same thing. However, in my personal opinion, writing
        procedures to require the adviser to be in charge of mutual fund anti-money
        laundering procedures seems like a backwards way of doing things.

        Vicki Hulick
        Director of Compliance
        Nicholas-Applegate Capital Management
        600 W. Broadway
        San Diego, CA 92101

        -----Original Message-----
        From: dbrown8289@... [mailto:dbrown8289@...]
        Sent: Monday, April 01, 2002 10:35 AM
        To: fundlaw@yahoogroups.com
        Subject: [FundLaw] Anti-Money Laundering Procedures


        Fundlaw Group,

        Our firm, Self Audit, Inc. has created model anti-money laundering
        procedures
        for mutual fund companies. These model procedures delegate the
        responsibility of having an AML Program to the Investment Adviser. We are
        in
        the process of completing an Investment Advisers AML Program Kit. This kit
        contains an employee training program (powerpoint slides), due diligence
        information on "covered service providers" and other relevant information.
        Any firm interested in obtaining this kit should register at our website
        (via
        the free download) at www.selfauditor.com. We are working feverishly to
        have
        this kit available by April 4th.

        In creating this program we reviewed pre-existing AML Procedures, the GAO
        Report on Anti-Money Laundering, ICI information, other similar procedures
        and various other sources. Although there is not much guidance on the
        requirements of a program, this program creates an initial structure whereby

        an investment adviser can become informed about anti-money laundering
        requirements.

        Regards,
        Debra Brown
        Self Audit, Inc.
        20 Oak Street
        Beverly Farms, MA 01915
        978.921.6688
        dbrown@...

        Please feel free to contact me directly at 978.921.6688. Have a great day!
      • dbrown8289@aol.com
        We request the opportunity to respond to Ms. Hulick s email. Self Audit, Inc. has made available model anti-money laundering procedures to the investment
        Message 3 of 3 , Apr 2, 2002
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          We request the opportunity to respond to Ms. Hulick's email.

          Self Audit, Inc. has made available "model anti-money laundering procedures" to the investment regulatory community to assist with the April 24th compliance date. The "model procedures" may be tailored to delegate AML Program responsibility to various entities including fund administrators, broker/dealers and/or transfer agents. As Ms. Hulick stated, each organization is in the best position to evaluate what structure works best for that organization.

          In creating our "model" procedures, we reviewed how procedures of this nature were delegated historically with mutual funds. Some recent examples include Rule 17j-1 requirements and fair valuation procedures. Also, for many mutual funds, the Investment Adviser establishes selling agreements and oversees the service providers for the mutual funds. Our model enables the mutual fund board members to review compliance reports, rather than each service organization's AML program information.

          Our AML Program Kit for Investment Advisers may also be customized for use by administrators and/or broker/dealers. It is always difficult to construct a model that will work for every organization. We believe that these model procedures are useful to firms that have not yet created their AML Program.

          Thank you for your interest.

          Regards,
          Debra Brown
          President
          Self Audit, Inc.
          20 Oak Street
          Beverly Farms, MA 01915
          978.921.6688
          dbrown@...
          www.selfauditor.com
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