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Financial Institutions Exempt Reporting Advisers (ERAs) Anti-Money Laundering

ArentFox Schiff

FinCEN Releases Final Anti-Money Laundering Rule for Investment Advisers

ArentFox Schiff on

On August 28, the Financial Crimes Enforcement Network (FinCEN) issued a final rule establishing anti-money laundering and countering the financing of terrorism (AML/CFT) compliance obligations for US Securities and Exchange...more

K2 Integrity

Implementing FinCEN Final Rule Imposing Anti-Money Laundering Requirements On Investment Advisers

K2 Integrity on

On 28 August 2024, the Financial Crimes Enforcement Network (FinCEN) issued its Final Rulemaking to include certain investment advisers in the definition of a “financial institution” under the Bank Secrecy Act (BSA). The...more

Seward & Kissel LLP

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

Seward & Kissel LLP on

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

Seward & Kissel LLP

Q&A on FinCEN’s New AML Requirements for Certain Investment Advisers

Seward & Kissel LLP on

On August 28, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule (the “Final Rule”) that subjects certain registered investment advisers (“RIAs”) and exempt reporting advisers (“ERAs”) to anti-money...more

DLA Piper

National Security Risks Headline New AML Requirements for Investment Advisers – and More to Come?

DLA Piper on

Last week, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a widely anticipated final rule to police the estimated $125 trillion-plus investment adviser market. The new rule extends...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

Mayer Brown Free Writings + Perspectives

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

I. INTRODUCTION - On May 13, 2024, the US Securities and Exchange Commission (“SEC”) and the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a joint notice of proposed rulemaking (the...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

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

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

Seward & Kissel LLP

FinCEN Proposes New Rule to Subject Advisers to AML Requirements

Seward & Kissel LLP on

Who may be interested: Investment Advisers; Closed-End Funds; and Directors of Closed-End Funds - Quick Take: The U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) recently issued a notice of...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

Akin Gump Strauss Hauer & Feld LLP

FinCEN Proposes New Rule to Expand Anti-Money Laundering Requirements for Investment Advisers

Key Points - On February 13, 2024, FinCEN issued an NPRM that seeks to include certain investment advisers in the definition of “financial institution” under the BSA. As described in the NPRM as well as in FinCEN’s fact...more

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