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Clean capital, clear structures: ONS FinServ’s Anjana Raju on the future of fund compliance

As the global fund administration landscape grows increasingly complex, the role of compliance has moved far beyond box-ticking. Regulatory expectations are tightening, investor scrutiny is intensifying, and the demand for genuine operational rigour — from AML frameworks to continuous monitoring and cross-border data governance — has never been greater. For fund structures operating across multiple jurisdictions, the difference between credibility and vulnerability often comes down to the quality of the compliance architecture underpinning them.

ONS FinServ has positioned itself at the forefront of this shift, offering fund administration services that treat governance not as a back-office afterthought but as a core pillar of institutional trust. Anjana Raju, Senior Compliance Executive & MLRO at ONS FinServ, brings a practitioner’s perspective to some of the most pressing questions facing fund managers and administrators today. She shares her insights below.

1) Fund administration has evolved from a back-office utility into a core governance partner. How can administrators scale increasingly heavy AML and regulatory reporting burdens without compromising operational agility?

The answer is not simply adding more people; it is building a stronger operating model. At ONS FinServ, we look at AML, investor onboarding, FATCA/CRS, regulatory filings and ongoing monitoring as one connected governance workflow. The key is standardised checklists, risk-based escalation, strong technology, and experienced human review where judgement is needed. Agility comes when routine items are systemised, but exceptions are handled by senior compliance professionals. A fund administrator must help managers move faster, but never at the cost of regulatory comfort or auditability.

2) With investors demanding absolute transparency, what do you see as the greatest risk to a fund structure when the lines between internal management and independent administrative oversight become blurred?

The biggest risk is loss of trust. Investors rely on the administrator to provide an independent layer of discipline around NAV, investor records, AML files, reporting and governance evidence. If the administrator starts looking like an extension of the manager rather than an independent control function, even a technically sound fund can face credibility questions. At ONS FinServ, our role is to support the manager, but also preserve the integrity of the structure. That balance is exactly what institutional investors want to see.

3) Robust AML frameworks are increasingly viewed as a commercial asset that attracts institutional capital. How can managers leverage strict source-of-wealth verification as a “seal of quality” rather than a friction point?

Managers should position source-of-wealth checks as investor protection, not paperwork. Serious institutional investors understand that clean capital, verified beneficial ownership and documented source of funds reduce future regulatory, banking and reputational risk. The way to reduce friction is to explain requirements early, use clear document checklists, and apply a proportionate risk-based approach. At ONS FinServ, we help managers make AML part of their fund’s credibility story: “we know our investors, we know the capital, and we can evidence it.”

4) The regulatory shift from one-time investor onboarding to continuous dynamic monitoring is intensifying. What is the biggest operational hurdle in maintaining this level of perpetual compliance?

The biggest hurdle is keeping investor information live without overwhelming the business. A file that was clean at onboarding can become outdated because of sanctions changes, PEP status changes, ownership changes, jurisdictional risk, or unusual transaction activity. Continuous monitoring requires good data discipline, screening frequency, trigger-event reviews, and clear responsibility between the manager and administrator. At ONS FinServ, we focus on building monitoring calendars and escalation workflows so compliance does not become a last-minute scramble during audit, filing or regulator review.

5) As capital flows into Africa become more complex, do you see Mauritius and the DIFC as competing hubs, or is there a growing trend of funds leveraging the unique regulatory strengths of both?


I see them as increasingly complementary, not purely competing. Mauritius has deep experience as an Africa-focused fund domicile, strong treaty and regional familiarity, and a mature ecosystem for private equity and investment holding structures. DIFC brings proximity to global capital, DFSA regulation, institutional credibility and access to managers, family offices and investors in the Middle East. At ONS FinServ, we often look at structures practically: where should the fund sit, where should the manager sit, and what combination gives investors, banks and regulators the most comfort?

6) Reconciling fragmented compliance requirements across different borders is incredibly challenging. How do you successfully manage the friction between differing data privacy laws and strict sanctions screening?

The solution is to avoid treating privacy and sanctions as competing obligations. Both need to be built into the same compliance architecture. Sanctions screening requires timely access to accurate investor and beneficial ownership data, while data privacy requires purpose limitation, controlled access, secure storage and lawful transfers. At ONS FinServ, we manage this through clear consent language, data minimisation, documented transfer controls, approved screening tools, and audit trails. The objective is simple: screen effectively, protect personal data, and be able to evidence every decision.

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