Passthrough’s 2025 Private Markets Financial Crime Report analyzes data from 120+ fund managers and 10,000+ investors and beneficial owners — and surfaces a reality few managers are prepared for: sanctioned individuals, politically exposed persons, and high-risk entities are already inside investor bases.
This is the first time data at the investor level has been structured and analyzed across ownership chains, jurisdictional exposure, and screening results. Because Passthrough connects directly with investor submissions, we see what others can’t — and the risks are more widespread than you’d expect.
Key takeaways from the report:
• Sanctioned matches start around investor #415 — and increase from there
• Most investors aren’t individuals. 63% are entities with 3–5+ beneficial owners, often in high-risk jurisdictions
• Screening noise is massive. With 1,000 investors, expect ~5,000 alerts — and 96% of them are false positives
• Retroactive risk is real. Funds have already distributed capital to sanctioned or terrorism-linked individuals
With SEC and FinCEN rules going into effect in 2026, every RIA and ERA must have an AML program that applies to all investors — past and present.
This report breaks down what that means, what regulators expect, and where most firms are underestimating the risk.
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