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Financial Institutions › Investment Advisers Act of 1940 › Proposed Rules

Akin Gump Strauss Hauer & Feld LLP

FinCEN Delays Effective Date of Investment Adviser Rule and Intends to Revisit the SEC Customer Identification Program Rule for...

Akin Gump Strauss Hauer & Feld LLP on

In September 2024, FinCEN issued the Investment Adviser Rule, which aims to “address ongoing illicit finance risks, threats, and vulnerabilities posed by criminals and foreign adversaries that exploit the U.S. financial...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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