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Financial Institutions › Investment Advisers Act of 1940 › AML/CFT

Alston & Bird

FinCEN Delays Enforcement of Investment Adviser AML/CFT Rule

Alston & Bird on

Our Financial Services and Investment Funds Teams examine the delay by the Financial Crimes Enforcement Network (FinCEN) of the effective date for the Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT)...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

King & Spalding

Request for Comments on FinCEN and SEC rule on CIP

King & Spalding on

The SEC and FinCEN Request Comments on their Proposed Rule on Customer Identification Programs for Registered Investment Advisers and Exempt Reporting Advisers - The Securities and Exchange Commission (“SEC”) and the...more

Pillsbury Winthrop Shaw Pittman LLP

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

Pillsbury Winthrop Shaw Pittman LLP on

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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