A venture fund's screening problem is shaped by an asymmetry. Everything the fund controls happens in the weeks before the wire. Everything it is exposed to happens over the decade afterwards, inside companies it can influence but not direct.
That is the reverse of most AML relationships, where a firm retains the ability to restrict or exit and gets a stream of transactions to watch. Here the decision point arrives once, early, and then closes.
Why the pre-wire check carries more weight
An onboarding decision can be revisited. A bank can restrict an account, a fund manager can decline a subscription, and both keep the option to exit. A venture investment has no equivalent lever: illiquid, minority, and held for years.
So the diligence before the wire is not the first control among several. For much of the holding period it is the only one that was ever fully within the fund's gift.
The parties nobody onboarded
Each round adds names to the register. A Series B introduces investors the fund did not select, may not have met, and did not diligence, some of whom acquire information rights or board seats.
Treating the cap table as an attribute of the company misses this entirely. The register is a list of parties, and it changes without the fund doing anything. That is why new investors are marked as a distinct kind on the timeline above, alongside the acquirer at exit: they are not a change to an existing relationship, they are a new one.
The direction most funds forget
A fund screens its investments. It also has investors of its own, and subscription screening on limited partners is the obligation most often left to the administrator and assumed to be handled.
It runs on a different rhythm to portfolio work, because capital arrives at closes rather than at deal milestones, which is why it sits in the "running alongside" row rather than on the main line.
What an LP or a regulator asks later
Both ask the same question, years after the fact, about one specific decision: what did you know when you committed capital, and what did you do about it?
Answering means the record has to capture what was known at the time rather than what is known now. A file assembled retrospectively describes the present, which is not what either party is asking about.
For the sector view and its obligations, see the wealth and asset management industry page. For the underlying components, see enhanced due diligence and PEP and sanctions screening.
