Are PE / VC firms themselves AML-regulated?
In the UK and EU — yes; fund managers and certain advisers are obliged entities under the MLRs / AMLR. In the United States — investment advisers were not historically obliged entities under the BSA, but the FinCEN Investment Adviser Rule (finalised August 2024, effective 1 January 2026) brings SEC-registered investment advisers and exempt reporting advisers into the BSA framework with AML programme, SAR and recordkeeping obligations. In Australia — most fund managers are reporting entities under the existing 2006 Act for the financial-services they provide.