FinCEN’s announcement clearly reflected its sensitivity to industry concerns. It acknowledged that AML/CFT Rules “must be effectively tailored to the diverse business models and risk profiles of the investment adviser...more
7/29/2025
/ AML/CFT ,
Anti-Money Laundering ,
Business Model ,
Compliance ,
Effective Date ,
Financial Regulatory Reform ,
FinCEN ,
Investment Adviser ,
Proposed Rules ,
Regulatory Requirements ,
Rulemaking Process ,
Time Extensions ,
U.S. Treasury
On August 28, 2024, the Financial Crimes Enforcement Network (“FinCEN”) adopted final rules (“Rules”) applicable to investment advisers with relatively few changes from the rules as proposed....more
9/23/2024
/ AML/CFT ,
Anti-Money Laundering ,
Beneficial Owner ,
Compliance ,
Compliance Dates ,
Customer Due Diligence (CDD) ,
Final Rules ,
FinCEN ,
Investment Adviser ,
Proposed Rules ,
Registered Investment Advisors ,
Securities and Exchange Commission (SEC)
On May 13, 2024, the Securities and Exchange Commission (SEC) and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed rules (CIP Rules) that would impose customer identification...more
5/21/2024
/ AML/CFT ,
Comment Period ,
Compliance ,
Customer Identification Program (CIP) ,
Customer Information ,
FinCEN ,
Investment Adviser ,
Popular ,
Proposed Rules ,
Registered Investment Advisors ,
Securities and Exchange Commission (SEC)
On February 13, 2024, the U.S. Treasury Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking regarding a new proposed rule that would require certain investment advisers to apply anti-money...more
2/26/2024
/ AML/CFT ,
Anti-Money Laundering ,
Bank Secrecy Act ,
Beneficial Owner ,
Comment Period ,
Compliance ,
Examination Priorities ,
Exemptions ,
Financial Institutions ,
Financial Services Industry ,
FinCEN ,
Information Sharing ,
Investment Adviser ,
NPRM ,
Popular ,
Proposed Rules ,
Registered Investment Advisors ,
Risk Assessment ,
Securities and Exchange Commission (SEC) ,
Suspicious Activity Reports (SARs) ,
U.S. Treasury
On August 23, 2023, in a 3-2 vote, the U.S. Securities and Exchange Commission (the “SEC”) adopted new rules (the “Final Rules”) under the Investment Advisers Act of 1940 (the “Advisers Act”) primarily affecting investment...more
8/29/2023
/ Compliance ,
Disclosure Requirements ,
Final Rules ,
Investment Adviser ,
Investment Advisers Act of 1940 ,
Investors ,
Private Funds ,
Proposed Rules ,
Registered Investment Advisors ,
Regulatory Reform ,
Reporting Requirements ,
Securities and Exchange Commission (SEC) ,
Securities Regulation