Even though investment advisers are not subject to anti-money laundering regulations per se, examiners on both the state and SEC level expect advisors to have some minimal procedures in place. As a general rule, investment advisers are permitted to rely on certain third-party intermediaries to satisfy their anti-money laundering duties. Such third-party intermediaries include U.S.-regulated financial institutions such as the typical custodian used by most registered investment advisers (e.g., Schwab, Fidelity or TD Ameritrade). Investment advisers should, however, obtain one form of government issued identification (e.g., passport, driver’s license) to verify a client’s identity. In addition, an investment adviser should check all client names to ensure that the client does not appear on the Treasury’s OFAC “Specifically Designated Nationals and Blocked Persons” List and is not from, or engaging in transactions with people or entities from, embargoed countries and regions listed on the OFAC Web Site (www.treas.gov/ofac).

Not much heavy lifting here and well worth the added credibility it will give you with regulators.