Loading this page
Bringing the next page into view.
Blueprint Intelligence / Data Room and DDQ / Firm governance, risk, and compliance, the regulatory layer beyond the operational one
Data Room and DDQ
Operational due diligence tests whether a fund's infrastructure works. Governance, risk and compliance ask an adjacent question: can the firm demonstrate that it is properly registered and monitored under the obligations that apply to it?
Blueprint's operational due diligence checklist covers the infrastructure layer, cybersecurity, business continuity, a named compliance officer. This section of the DDQ sits next to that but asks a different question: whether the firm can demonstrate active regulatory compliance, meaning anti-money-laundering readiness, sanctions screening, a clean or disclosed regulatory history, and a written code of conduct governing how the firm itself behaves.
ILPA and ILPA DDQ are marks of the Institutional Limited Partners Association. Blueprint is not affiliated with, endorsed by, or certified by ILPA.
FinCEN deferred the effective date of its investment-adviser AML rule to January 1, 2028. That does not establish that every manager has no current anti-money-laundering or know-your-customer obligations: adviser status, jurisdiction, counterparties and other rules matter. Confirm the applicable requirements with counsel and compliance advisers. Describe current controls and any implementation work separately.
If an LP asks for a code of conduct, provide the current policy and explain the reporting channel, investigation process and non-retaliation arrangements it sets out. If work is still underway, identify the owner and next step. A policy should describe practices the firm can implement.
A future regulatory effective date and today’s diligence request are different things. Keep both visible, and confirm the firm’s actual obligations with its advisers.
Source check recorded: September 18, 2026 (claim-scope review).
This review checked the specific rule scope discussed above. It does not establish the requirements for your fund; confirm the applicable position with the authority and qualified advisers.
Check your compliance documentation
Upload one document containing your compliance manual, your conflicts of interest policy, or a description of your current regulatory readiness. No signup required for your first result.
One PDF or DOCX, up to 15 MiB. Three successful free reads are shared across the library; no account is needed. This is an initial review, not an eligibility decision or a fund rating.
Perspectives by Colibrí Strategies: practical notes for GPs and the LPs who back them.
Opens Substack in a new tab, where you confirm the subscription.
Upload the LP questionnaire and your current fund materials. Blueprint drafts what the evidence supports and flags what still needs your confirmation.