The SEC settled charges against a registered investment adviser for making false statements about its anti-money laundering (AML) procedures and for compliance failures. From October 2018 to January 2022, the adviser misled investors by claiming it voluntarily complied with AML due diligence laws, even though these laws did not apply to investment advisers in the U.S. The firm represented that it conducted AML due diligence on investors, but it failed to do so consistently, including with respect to an entity linked to a person with suspected money laundering connections. The SEC found that the adviser failed to adopt and implement written policies reasonably designed to ensure the accuracy of its offering documents. The adviser agreed to pay a $150,000 civil penalty. This case highlights the importance of ensuring your compliance program is more than words on a page.