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AML/CFT Investment Adviser Proposed Rules

BCLP

FinCEN Adopts AML/CFT Rules for Investment Advisers with Few Changes from Proposed Rules

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On August 28, 2024, the Financial Crimes Enforcement Network (“FinCEN”) adopted final rules (“Rules”) applicable to investment advisers with relatively few changes from the rules as proposed....more

K2 Integrity

[Webinar] Pending FinCEN Investment Advisor Rule: Industry Perspective on Next Steps You Should Be Taking - August 22nd, 12:30 pm...

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Join our panel of experts for a 60-minute session to discuss the pending Financial Crimes Enforcement Network (FinCEN) Investment Advisory Rule and what steps industry should be taking to prepare. The panel will include Sarah...more

K2 Integrity

AML/CFT Rules for Investment Advisers

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On 12 June 2024, K2 Integrity and Schulte Roth & Zabel hosted a webinar discussing new regulatory obligations anticipated under proposed rules for investment advisers (IAs), timelines for finalization and compliance, and how...more

Dechert LLP

SEC, FinCEN Propose CIP Rules for Investment Advisers

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The Proposed Rule would require registered investment advisers (RIAs) and exempt reporting advisers (ERAs) to establish, document and maintain written customer identification programs (CIPs). The Proposed Rule comes...more

Latham & Watkins LLP

SEC and FinCEN’s Proposed AML Rule Could Increase Compliance Burden on Investment Advisers

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RIAs and ERAs may soon be required to implement procedures to verify their clients’ identities. On May 13, 2024, the Securities and Exchange Commission (SEC) and the US Department of the Treasury’s Financial Crimes...more

Davis Wright Tremaine LLP

Broker Dealer Regulatory Digest - May 2024 - 2

Securities and Exchange Commission. Customer ID requirements. On May 13, 2024, SEC and FinCEN proposed a rule designed to make it more difficult for criminal actors to establish customer relationships with investment...more

Royer Cooper Cohen Braunfeld LLC

SEC & FinCEN Propose Customer Identification Program Requirements

A press release was recently issued describing a significant joint proposal by the Securities and Exchange Commission (SEC) and the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN). The proposal...more

BCLP

SEC and FinCEN Propose Rules to Impose Customer Identification Program Obligations on Certain Investment Advisers

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On May 13, 2024, the Securities and Exchange Commission (SEC) and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed rules (CIP Rules) that would impose customer identification...more

Ballard Spahr LLP

Treasury Issues Broad National Strategy for Combatting Illicit Financing

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Strategy Touts Regulations on Beneficial Ownership, Real Estate and Investment Advisers, but Bemoans Lack of Supervisory Resources for Non-Bank Financial Institutions...more

Goodwin

FinCEN (and SEC) Propose New Customer Identification Program Rule With Minimal Expected Impact on Private Fund Sponsors

Goodwin on

On May 13, 2024, the Financial Crimes Enforcement Network (FinCEN), a bureau within the U.S. Treasury Department, and the Securities and Exchange Commission (SEC) proposed a joint rule (the Proposed Rule) with respect to a...more

K2 Integrity

[Webinar] AML/CFT Rules for Investment Advisers - June 12th, 9:30 am PT

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On 13 February 2024, the Financial Crimes Enforcement Network (FinCEN) issued a groundbreaking Notice of Proposed Rulemaking (NPRM) to combat illicit finance and national security threats in the investment adviser sector. The...more

Morgan Lewis

FINCEN’s AML Proposal: An Overview for Investment Advisers

Morgan Lewis on

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...more

Pillsbury Winthrop Shaw Pittman LLP

FinCEN’s Proposed Rule to Regulate Investment Advisers: The Questions Industry Should Be Following

FinCEN is focused on customer due diligence, and both the 2024 Investment Adviser Risk Assessment and proposed rule indicate that investment advisers will be expected to assess customer identity, business model, and sources...more

ArentFox Schiff

Investment Advisers To Be Subject to Strengthened AML Regulations Under FinCEN’s Proposed Rule

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On February 13, the US Department of the Treasury’s (USDT) Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (NPRM) which, if adopted, would sweep Security and Exchange Commission-Registered...more

Ballard Spahr LLP

FinCEN Seeks to Make Investment Advisers Subject to Bank Secrecy Act

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Years in the making, on February 13, the Financial Crimes Enforcement Network (“FinCEN”) issued a notice of proposed rulemaking (“NPRM”) to include “investment adviser” (“IA”) within the definition of “financial institution”...more

DarrowEverett LLP

Investment Advisors Face Added Regulation That Could Potentially Impact Litigation

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On February 13, 2024, FinCEN issued a Notice of Proposed Rulemaking (NPRM) to deter criminals and foreign adversaries who seek to potentially compromise the U.S. financial system and assets through investment advisors. If...more

Vedder Price

FinCEN Proposes Rule to Address Anti-Money Laundering Risks to Registered Investment Advisers and Exempt Reporting Advisers

Vedder Price on

On February 13, 2024, the Financial Crimes Enforcement Network (FinCEN) issued a proposed rule1 that would extend certain anti-money laundering/countering the financing of terrorism (AML/CFT) program requirements to...more

Troutman Pepper

FinCEN Proposes New Investment Adviser AML Rule

Troutman Pepper on

On February 1/3, the Financial Crimes Enforcement Network (FinCEN) proposed a new rule (the Proposed Rule), that, if adopted, would add certain investment advisers to the definition of “financial institution” under the Bank...more

K2 Integrity

Proposed Rule to Impose Anti-Money Laundering Requirements on Investment Advisers

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On 13 February 2024, the Financial Crimes Enforcement Network (FinCEN) issued a groundbreaking Notice of Proposed Rulemaking (NPRM) to combat illicit finance and national security threats in the investment adviser sector. The...more

King & Spalding

FinCEN Proposes Rule to Extend Bank Secrecy Act Obligations to Certain Investment Advisers

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The Proposed Rule Would Subject Certain Investment Advisers to a Broad Range of AML/CFT Obligations and Represents a Significant Development for the Sector - Regulators have long considered the lack of anti-money...more

BCLP

FinCEN Proposes AML/CFT Rules for Investment Advisers

BCLP on

On February 13, 2024, the U.S. Treasury Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking regarding a new proposed rule that would require certain investment advisers to apply anti-money...more

Stinson LLP

FinCEN Proposes Expanding AML Rules to Investment Advisers

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On February 13, 2024, the Financial Crimes Enforcement Network (FinCEN) of the U.S. Department of Treasury (Treasury) issued a "Notice of proposed rulemaking" (proposed rule) that would require Securities Exchange Commission...more

White & Case LLP

FinCEN Again Proposes Sweeping AML Requirements for Registered Investment Advisers & ERAs

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On February 13, 2024, FinCEN proposed a long-awaited rule to combat illicit finance and national security threats in the asset management industry. The new rule would impose similar requirements on investment advisers that...more

Holland & Knight LLP

FinCEN Proposal Potentially Impacts Registered Investment, Exempt Reporting Advisers

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The U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) has issued a new notice of proposed rulemaking (NPRM), referred to herein as the "Proposed Rule," that would subject SEC-registered...more

Goodwin

FinCEN Proposes AML Program Rule for Investment Advisers

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The Financial Crimes Enforcement Network (“FinCEN”), a bureau within the U.S. Treasury Department, has issued a proposed rule (the “Proposal”) that would subject certain investment advisers to anti-money laundering (“AML”)...more

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