AML and Sanctions Policy Template for Investment Advisers
OFAC regulations (31 CFR Chapter V) and FinCEN's investment adviser AML rule
Sanctions screening, investor identification and due diligence, red flags and suspicious activity, and a plan for FinCEN's anti-money laundering rule for advisers.
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What the rule requires
U.S. sanctions apply to every U.S. person today: an adviser must not deal with sanctioned persons or countries, and screening investors and counterparties is how firms meet that. Knowingly handling the proceeds of crime is a federal offence whether or not an AML program is required.
FinCEN adopted a rule in 2024 requiring most SEC-registered advisers and exempt reporting advisers to maintain AML/CFT programs and file suspicious activity reports. Its effective date is now January 1, 2028, and FinCEN has said it will revisit the rule's scope, so the policy includes a voluntary program today and readiness steps for the rule.
What the policy covers
The sections of Luna's model Anti-Money Laundering and Sanctions policy. Your draft includes only the clauses that apply to your firm.
- 1Purpose and scope
- 2Sanctions (OFAC)
- 3Investor identification and due diligence
- 4Suspicious activity
- 5Cash and currency reporting
- 6AML/CFT program (FinCEN rule)
- 7Training and records
What Luna asks you
A few of the questions that shape the draft:
- Who runs the AML and sanctions program
- What the firm uses for sanctions screening
- Who performs investor due diligence
- Whether the firm is adopting the FinCEN program early
How drafting works
- 01Answer questions about your firm
Plain questions about how you operate. Where there is a common answer, Luna suggests it; where you are not sure, say so and it is flagged rather than assumed.
- 02Luna drafts the policy
Only the clauses that apply to your firm, in your firm's name, each traced to the rule or choice it comes from.
- 03Review what is left
Anything unanswered is marked in the text and listed for you, and the policy cannot be approved until each is settled.
- 04Edit, approve and roll out
It is your policy: edit it like any other, approve it, and have employees acknowledge it in the same place.
Other policies
A summary of what the rule requires, current as of October 2026, so you can see what the policy covers. It is not legal advice. A policy drafted in Luna is your firm's draft to review, edit and adopt.