On August 25, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) released a Notice of Proposed Rulemaking (NPRM), which would impose anti-money laundering (AML), suspicious activity reporting, currency transaction reporting, and information sharing obligations on investment advisers. The NPRM was published in the Federal Register on September 1 (80 FR 52680). Persons interested in commenting on the proposed rule will have until November 2 to file comments, after which FinCEN will issue a final rule.

The proposed rule follows a decade of FinCEN’s efforts to regulate investment advisers and unregistered investment companies in an evolving financial environment. This proposed rule envisions the following key changes to FinCEN’s regulations.