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Investment Advisers Prepare: The BSA is Here

On August 28, the United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (the “Final Rule”) subjecting certain registered investment advisers (RIAs) and exempt reporting...more

SEC and FinCEN Propose Customer Identification Obligations for Investment Advisers

On May 13, the Securities and Exchange Commission (SEC) and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released a joint notice of a proposed rulemaking (NPRM) that would require...more

AML Best Practices for Private Fund Managers: The Prudence of Establishing an AML Compliance Program

I. Introduction- U.S. hedge funds, private equity funds, and venture capital funds (collectively, the Private Funds),1 and their U.S. general partners, sponsors, and managers (Advisers), are not directly subject to the...more

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