News & Analysis as of

Investment Adviser Patriot Act Suspicious Activity Reports (SARs)

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

Lowenstein Sandler LLP

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

K2 Integrity

AML/CFT Rules for Investment Advisers

K2 Integrity on

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

Foodman CPAs & Advisors

Director Gacki From FinCEN Encourages Transparency In The U.S. Financial System

During the FIBA’s (Financial and International Business Association’s) annual anti-money laundering conference held from March 18, 2024, to March 21, 2024 in Miami, Florida, Director Gacki from FinCEN discussed regulatory...more

Dechert LLP

Treasury Proposes Investment Advisers AML/CFT Program Rule

Dechert LLP on

Treasury proposed a new rule that would require investment advisers to establish an AML/CFT program and file certain reports, such as Suspicious Activity Reports (SARs), with FinCEN (Proposed Rule). The Proposed Rule...more

ArentFox Schiff

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

ArentFox Schiff on

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

K2 Integrity

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

K2 Integrity on

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

King & Spalding on

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

Lowenstein Sandler LLP

Investment Advisers Beware: The BSA is Coming (Maybe)

Lowenstein Sandler LLP on

The United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has issued a notice of proposed rulemaking (NPRM) that would subject registered investment advisers (RIAs) and exempt reporting...more

Troutman Pepper

FinCEN's Recently Proposed AML Rule: A Road Map for SEC-Registered Investment Advisers

Troutman Pepper on

The U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (the Proposed Rule) on September 1, 2015 that would impose anti-money laundering (AML) requirements for investment...more

Baker Donelson

Advisers Charged with Cleansing Dirty Money from Industry

Baker Donelson on

On August 25, 2015, the Financial Crimes Enforcement Network (FinCEN) proposed an anti-money laundering rule applicable to SEC-registered investment advisers (RIAs). The proposed rule would require RIAs to establish...more

Proskauer - Corporate Defense and Disputes

Proposed AML Regulations for Registered Investment Advisers Released by FinCEN

On August 25, 2015, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released proposed rules that would require investment advisers that are registered or required to be registered (RIAs)...more

Morgan Lewis

AML Requirements Proposed for SEC Registered Advisers

Morgan Lewis on

On August 25, the Financial Crimes Enforcement Network (FinCEN), a bureau of the US Department of the Treasury (Treasury), published a notice of proposed rulemaking (NPRM) to impose anti-money laundering (AML) programs and...more

Orrick, Herrington & Sutcliffe LLP

FinCEN Proposes New Rule Requiring Anti-Money Laundering Programs for Registered Investment Advisers

On August 25, 2015, the Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking (NPRM) that would define investment advisers registered (or required to be registered) with the Securities and...more

Morrison & Foerster LLP

FinCEN Proposes Anti-Money Laundering Rules for Registered Advisers

The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) on August 25, 2015 proposed rules to require SEC- registered investment advisers to adopt and maintain anti-money laundering (AML) programs and to...more

Goodwin

FinCEN Proposes AML Program Rule for Investment Advisers

Goodwin on

The Financial Crimes Enforcement Network (FinCEN) has issued a proposed rule that would subject certain investment advisers to AML requirements under the Bank Secrecy Act (the BSA). In proposing the rule, FinCEN cited...more

Stinson - Corporate & Securities Law Blog

FinCEN Proposes Extending Anti-Money Laundering Compliance Requirements to Investment Advisers

On Tuesday, the United States Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed a rule that would require SEC-registered investment advisers, including private equity and hedge funds, to comply...more

McGuireWoods LLP

FinCEN Proposes Rule Requiring Investment Advisor AML Compliance

McGuireWoods LLP on

Investment advisors may soon face increased costs and scrutiny thanks to a proposed rule issued by the Financial Crimes Enforcement Network (FinCEN). On Tuesday, August 28, FinCEN proposed a rule that would require many...more

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