News & Analysis as of

Anti-Money Laundering Customer Identification Program (CIP) Exempt Reporting Advisers (ERAs)

Goodwin

FinCEN to Postpone Effective Date and Reopen Anti-Money Laundering Rule for Investment Advisers

Goodwin on

On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intent to postpone the effective date of the Anti-Money Laundering/Countering the Financing of Terrorism...more

K2 Integrity

Implementing FinCEN Final Rule Imposing Anti-Money Laundering Requirements On Investment Advisers

K2 Integrity on

On 28 August 2024, the Financial Crimes Enforcement Network (FinCEN) issued its Final Rulemaking to include certain investment advisers in the definition of a “financial institution” under the Bank Secrecy Act (BSA). The...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

King & Spalding

FinCEN Issues Final Rule Expanding Anti-Money Laundering/ Countering the Financing of Terrorism Requirements for Investment...

King & Spalding on

On September 4, 2024, the Financial Crimes Enforcement Network (“FinCEN”), U.S. Department of Treasury, published a final rule (the “Final Rule”) expanding the definition of “financial institution” under the Bank Secrecy Act...more

K&L Gates LLP

AML Update: SEC and FinCEN Propose Anti-Money Laundering and Customer Identification Programs for Investment Advisers

K&L Gates LLP on

Introduction - On 13 May 2024, the Securities and Exchange Commission (SEC) and the US Department of Treasury’s (DoT) Financial Crimes Enforcement Network (FinCEN) jointly proposed rulemaking to implement Section 326 of the...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

Guidepost Solutions LLC

Money Laundering, Terrorist Financing, and Investment Advisors – Yes, Financial Crime is Borderless and Legal Entity-Agnostic

There is a growing acknowledgement that money laundering and terrorist financing is borderless and legal entity-agnostic, just as it is already known that cybercriminals and the means to commit cybercrimes continuously attack...more

Cooley LLP

SEC, FinCEN Propose to Mandate Customer Identification Programs for Registered Investment Advisers, Exempt Reporting Advisers

Cooley LLP on

On May 13, 2024, the US Securities and Exchange Commission (SEC) and the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) jointly issued a notice of proposed rulemaking that would require investment...more

Katten Muchin Rosenman LLP

Customer Identification Program Requirements for Investment Advisers

On May 13, the Securities and Exchange Commission (SEC) and the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) jointly proposed to require that SEC-registered investment advisers (RIAs) and...more

Pillsbury Winthrop Shaw Pittman LLP

FinCEN’s Proposed Rule to Regulate Investment Advisers: The Questions Industry Should Be Following

FinCEN is focused on customer due diligence, and both the 2024 Investment Adviser Risk Assessment and proposed rule indicate that investment advisers will be expected to assess customer identity, business model, and sources...more

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