On December 1, 2007 Midsea Consulting Limited (MCL) entered into a licensing agreement with Epiphany Financial Services (EFS) to provide Anti-Money Laundering (AML) services to Hedge Fund Managers and Fund Administration companies.
The licensing agreement provides for MCL to administer an AML compliance program developed by EFS. Currently we are servicing one Fund Administration company in Bermuda. The product is a turn-key anti-money laundering/anti-terrorist financing procedures program which is compliant with the USA PATRIOT Act and the laws of Bermuda, British Virgin Islands, Cayman Islands and Ireland.
The AML compliance program was designed specifically for hedge funds, in order to take into account the unique challenges presented by their diverse, and sometimes, complex investor base.
The AML program adopts a "risk based" compliance process, requiring each fund to examine their investor base and tailor their compliance program to address the risks presented by that investor base. Resources are focused on those investors determined to be high risk whereas low risk investors need not be subjected to the same level of scrutiny. High risk investors are subjected to enhanced due diligence, including cross checking high risk investors against a database of known or suspected money launders, terrorists and other high risk persons. The AML program incorporates a detailed risk assessment of the nine different types of hedge fund investors and provides for appropriate treatment for each depending upon their unique risk characteristics.
MCL prepares a customized report detailing the due diligence carried out together with an assessment as to whether it is appropriate to admit the investor into the fund.
Once an investor has been reviewed and admitted into the fund, MCL adds it to a database of "Approved Financial Institutions" to ensure the investor is not inconvenienced by additional requests for AML information. The effect is an organized and efficient risk-based AML process which benefits both investors and hedge fund administrators.