FINCEN’s AML Proposal: An Overview for Investment Advisers

Earlier this year, the US Department of the Treasury’s (Treasury’s) Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (the Proposal) that would subject investment advisers to anti-money laundering/countering the financing of terrorism (AML/CFT) programs and related reporting requirements, including suspicious activity reports (SARs).

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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