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Patriot Act Beneficial Owner Exempt Reporting Advisers (ERAs)

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

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

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