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Suspicious Activity Reports (SARs) Exempt Reporting Advisers (ERAs) Customer Due Diligence (CDD)

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

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

Paul Hastings LLP

FinCEN Proposes AML and SAR Filing Obligations for RIAs and ERAs

Paul Hastings LLP on

On February 13, 2024, the United States Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a proposed rule that would apply comprehensive anti-money laundering and countering the financing of terrorism...more

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