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Bank Secrecy Act Postponed for Investment Advisers and Exempt Reporting Advisers

On July 21, the United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intent to postpone compliance with new regulatory requirements imposing certain anti-money laundering...more

Investment Advisers Prepare: The BSA is Here

On August 28, the United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (the “Final Rule”) subjecting certain registered investment advisers (RIAs) and exempt reporting...more

SEC and FinCEN Propose Customer Identification Obligations for Investment Advisers

On May 13, the Securities and Exchange Commission (SEC) and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released a joint notice of a proposed rulemaking (NPRM) that would require...more

Investment Advisers Beware: The BSA is Coming (Maybe)

The United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has issued a notice of proposed rulemaking (NPRM) that would subject registered investment advisers (RIAs) and exempt reporting...more

U.S. Treasury Renews Push to Make Investment Advisers Subject to the BSA

The United States Department of the Treasury (U.S. Treasury) announced that it aims to publish a proposed rule in early 2024 (the 2024 NPRM) that would subject investment advisers to the anti-money laundering (AML)...more

AML Best Practices for Private Fund Managers: The Prudence of Establishing an AML Compliance Program

I. Introduction- U.S. hedge funds, private equity funds, and venture capital funds (collectively, the Private Funds),1 and their U.S. general partners, sponsors, and managers (Advisers), are not directly subject to the...more

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