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U.S. Treasury Investment Adviser Customer Identification Program (CIP)

Troutman Pepper

Treasury Department Releases Semiannual Regulatory Agenda

Troutman Pepper on

On August 16, the U.S. Department of the Treasury published its semiannual regulatory agenda in the Federal Register, detailing the agency’s upcoming regulatory actions and priorities. The agenda outlines the proposed, final,...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

Dechert LLP

Treasury Issues Final Investment Advisers AML/CFT Program Rule

Dechert LLP on

Treasury issued a final rule requiring certain investment advisers to establish an AML/CFT Program and file certain reports, such as Suspicious Activity Reports (SARs), with FinCEN (Final Rule). The Final Rule applies to...more

Morrison & Foerster LLP

FinCEN & the SEC: Will the Real RIA and ERA Customers Please Stand Up?

On May 13, 2024, the U.S. Department of the Treasury’s (“Treasury”) Financial Crimes Enforcement Network (FinCEN) and the Securities and Exchange Commission (SEC) issued a joint Notice of Proposed Rulemaking (NPRM) that would...more

ArentFox Schiff

SEC and FinCEN Propose New Rule: Mandatory Customer Verification for Investment Advisers in 2024

ArentFox Schiff on

On May 13, the US Securities and Exchange Commission (SEC) and the US Department of the Treasury’s (USDT) Financial Crimes Enforcement Network (FinCEN) jointly released a notice of proposed rulemaking (NPRM) which, if...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

Akin Gump Strauss Hauer & Feld LLP

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

In February 2024, the U.S. Department of the Treasury issued its 2024 Investment Adviser Risk Assessment, which explains that there are “several illicit finance threats involving investment advisers,” including that...more

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