News & Analysis as of

Investment Adviser SIFMA Anti-Money Laundering

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

Morgan Lewis

SEC Extends AML Relief for Broker-Dealer CIP Reliance on Advisers

Morgan Lewis on

The SEC’s action suggests that formal antimoney laundering program requirements for investment advisers may be on the horizon. On January 9, the staff of the U.S. Securities and Exchange Commission (SEC) issued the...more

Katten Muchin Rosenman LLP

SEC Extends No-Action Letter Permitting Broker-Dealers to Rely on Certain Investment Advisers to Conduct Customer Identification...

The Securities and Exchange Commission has extended a no-action letter dated February 12, 2004 (the 2004 Letter) from the Securities Industry Financial Markets Association (SIFMA) that permits broker-dealers, subject to...more

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