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Customer Identification Program (CIP) Exempt Reporting Advisers (ERAs) Investment Adviser

Seward & Kissel LLP

Department of the Treasury Releases New AML/CFT Rule for Investment Advisers

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Who may be interested: Investment Advisers - Quick Take: The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule subjecting certain registered investment advisers (RIAs) and...more

King & Spalding

FinCEN Issues Final Rule Expanding Anti-Money Laundering/ Countering the Financing of Terrorism Requirements for Investment...

King & Spalding on

On September 4, 2024, the Financial Crimes Enforcement Network (“FinCEN”), U.S. Department of Treasury, published a final rule (the “Final Rule”) expanding the definition of “financial institution” under the Bank Secrecy Act...more

Morrison & Foerster LLP

FinCEN & the SEC: Will the Real RIA and ERA Customers Please Stand Up?

On May 13, 2024, the U.S. Department of the Treasury’s (“Treasury”) Financial Crimes Enforcement Network (FinCEN) and the Securities and Exchange Commission (SEC) issued a joint Notice of Proposed Rulemaking (NPRM) that would...more

K&L Gates LLP

AML Update: SEC and FinCEN Propose Anti-Money Laundering and Customer Identification Programs for Investment Advisers

K&L Gates LLP on

Introduction - On 13 May 2024, the Securities and Exchange Commission (SEC) and the US Department of Treasury’s (DoT) Financial Crimes Enforcement Network (FinCEN) jointly proposed rulemaking to implement Section 326 of the...more

ArentFox Schiff

SEC and FinCEN Propose New Rule: Mandatory Customer Verification for Investment Advisers in 2024

ArentFox Schiff on

On May 13, the US Securities and Exchange Commission (SEC) and the US Department of the Treasury’s (USDT) Financial Crimes Enforcement Network (FinCEN) jointly released a notice of proposed rulemaking (NPRM) which, if...more

Dechert LLP

SEC, FinCEN Propose CIP Rules for Investment Advisers

Dechert LLP on

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

Seward & Kissel LLP

SEC and FinCEN Propose Customer Identification Program Requirements for Registered Investment Advisers and Exempt Reporting...

Seward & Kissel LLP on

Who may be interested: Investment Advisers - Quick Take: On May 13, 2024, the SEC and the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) jointly proposed a new rule that would require certain...more

Eversheds Sutherland (US) LLP

FinCEN and SEC propose Customer Identification Program requirements for investment advisers

Earlier this month, the Financial Crimes Enforcement Network (FinCEN) continued its efforts to require registered investment advisers (RIAs) and exempt reporting advisers (ERAs) to take steps to prevent the laundering of...more

Ballard Spahr LLP

FinCEN and SEC Propose Rulemaking Requiring CIP for Investment Advisers

Ballard Spahr LLP on

On May 13th, the Financial Crimes Enforcement Network (FinCEN) and the Securities Exchange Commission (SEC) issued a joint notice of proposed rulemaking (NPRM) that would require SEC-registered investment advisers (RIAs) and...more

King & Spalding

Request for Comments on FinCEN and SEC rule on CIP

King & Spalding on

The SEC and FinCEN Request Comments on their Proposed Rule on Customer Identification Programs for Registered Investment Advisers and Exempt Reporting Advisers - The Securities and Exchange Commission (“SEC”) and the...more

Guidepost Solutions LLC

Money Laundering, Terrorist Financing, and Investment Advisors – Yes, Financial Crime is Borderless and Legal Entity-Agnostic

There is a growing acknowledgement that money laundering and terrorist financing is borderless and legal entity-agnostic, just as it is already known that cybercriminals and the means to commit cybercrimes continuously attack...more

Cooley LLP

SEC, FinCEN Propose to Mandate Customer Identification Programs for Registered Investment Advisers, Exempt Reporting Advisers

Cooley LLP on

On May 13, 2024, the US Securities and Exchange Commission (SEC) and the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) jointly issued a notice of proposed rulemaking that would require investment...more

Akin Gump Strauss Hauer & Feld LLP

SEC and FinCEN Propose Customer Identification Program Requirements for Certain Investment Advisers

In February 2024, the U.S. Department of the Treasury issued its 2024 Investment Adviser Risk Assessment, which explains that there are “several illicit finance threats involving investment advisers,” including that...more

Katten Muchin Rosenman LLP

Customer Identification Program Requirements for Investment Advisers

On May 13, the Securities and Exchange Commission (SEC) and the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) jointly proposed to require that SEC-registered investment advisers (RIAs) and...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

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