AML/CTF Reform and the Quality of Risk Decisions
A complete investor record is not always decision-ready. Australia’s AML/CTF reforms place more weight on the quality of risk decisions, and Wicklow’s Complete File Test offers a practical way to separate information gaps from judgement points.
The Onboarding Balancing Act
In wholesale funds, onboarding is the first real test of your operating model. Done well, it builds investor trust; done poorly, it undermines confidence before capital is even deployed.