News & Analysis as of August 11, 2025

Investment Advisers Act of 1940

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The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury charged with detecting and combatting illegal activity within the financial system. FinCEN detects evidence of money laundering, terrorist financing and other financial crimes by collecting, monitoring, and analyzing financial transaction data. Such data is disseminated to both domestic and international law enforcement agencies. less -

FinCEN Delays Enforcement of Investment Adviser AML/CFT Rule

Alston & Bird on 7/29/2025

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

FinCEN Postpones Investment Adviser AML Requirements, Buying Time for Revisions

Seward & Kissel LLP on 7/24/2025

On July 21, 2025, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) announced that it was delaying the effective date of its final rule establishing Anti-Money Laundering/Countering the Financing...more

SEC Charges Navy Capital in AML Failures: Say What You Do and Do What You Say

ArentFox Schiff on 1/29/2025

The US Securities and Exchange Commission (SEC) released a press release on January 15 announcing that it had charged Navy Capital Green Management, LLC, an investment adviser, with violations of the Investment Advisers Act...more

New FinCEN Rule Imposes AML Requirements on Investment Advisers

Neal, Gerber & Eisenberg LLP on 10/16/2024

On August 28, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule (the “Final Rule”) that will define most SEC-registered investment advisers (“RIAs”) and exempt reporting advisers (“ERAs”) as...more

FinCEN Proposes Rule to Extend Bank Secrecy Act Obligations to Certain Investment Advisers

King & Spalding on 2/27/2024

The Proposed Rule Would Subject Certain Investment Advisers to a Broad Range of AML/CFT Obligations and Represents a Significant Development for the Sector - Regulators have long considered the lack of anti-money...more

Investment Management Update - October 2015

Ballard Spahr LLP on 10/15/2015

Below is a summary of recent investment management developments that affect registered investment companies, private equity funds, hedge funds, investment advisers, and others in the investment management industry. Schwab...more

FinCEN Proposes New Anti-Money Laundering Rule For Investment Advisers

King & Spalding on 9/2/2015

On August 25, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) released a Notice of Proposed Rulemaking (NPRM), which would impose anti-money laundering (AML), suspicious activity reporting,...more

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