News & Analysis as of August 17, 2025

FinCEN › Investment Management

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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 -

Treasury Postpones Effective Date of Investment Adviser AML Rule, Plans Revisions

Wilson Sonsini Goodrich & Rosati on 7/30/2025

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has announced that it intends to postpone the effective date of the final rule establishing anti-money laundering (AML) and suspicious...more

Investment adviser anti-money laundering rule postponed and reopened for further review

Eversheds Sutherland (US) LLP on 7/24/2025

On July 21, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to delay the effective date for certain investment advisers to implement anti-money...more

United States: AML Reprieve for Investment Advisers

K&L Gates LLP on 7/23/2025

On July 21, 2025, the Financial Crimes Enforcement Network (FinCEN) announced that it is delaying the effective date of the investment adviser anti-money laundering rule (IA AML Rule) for two years from 1 January 2026 to 1...more

FinCEN Postpones Effective Date of AML/CFT Rule for Investment Advisers

Morrison & Foerster LLP on 7/23/2025

On July 21, 2025, the U.S. Department of the Treasury’s (“Treasury”) Financial Crimes Enforcement Network (FinCEN) announced it will delay the effective date of the final rule establishing anti-money laundering/countering the...more

BREAKING: FinCEN Postpones Effective Date of Investment Adviser AML Rule

Mayer Brown on 7/22/2025

Earlier yesterday, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to postpone the effective date of the final rule establishing Anti-Money Laundering/Countering the...more

Investment Adviser Compliance with FinCEN’s AML/CFT Rule

Dorsey & Whitney LLP on 7/9/2025

On August 28, 2024, Financial Crimes Enforcement Network (FinCEN) issued a final rule (the “Final Rule”) that imposes comprehensive anti-money laundering and countering the financing of terrorism (“AML/CFT”) requirements on...more

The BSA’s Expansion & How Investment Advisers Can Leverage Existing AML Compliance Programs in the Cayman Islands To Comply With...

Lowenstein Sandler LLP on 6/24/2025

On Aug. 28, 2024, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (the Final Rule) extending the scope of the Bank Secrecy Act (BSA) and its amendments by requiring certain...more

Understanding FinCEN’s New AML/CFT Rule for Investment Advisers

Procopio, Cory, Hargreaves & Savitch LLP on 5/20/2025

What You Need to Know Before January 1, 2026 - Certain registered investment advisers (RIAs) and Exempt Reporting Advisors (ERAs) will face new federal compliance and filing requirements in the new year. Starting January 1,...more

Recent SEC AML Enforcement Actions and Likely Continued AML Emphasis Under New Administration

Carlton Fields on 4/30/2025

Registered investment advisers have until January 1, 2026, to comply with the anti-money laundering (AML) compliance provisions of the Bank Secrecy Act (BSA). However, the SEC has recently charged two investment advisers with...more

February and March 2025 Regulatory Roundup

SEC Compliance Consultants, Inc. (SEC³) on 4/7/2025

SEC Clarifies Marketing Rule, Warms up to Crypto and Private Placements under 506(c), and Backs off Form SHO; Latest Lessons from EXAMS: Duty of Care and Risk Identification Failures - Welcome to our February and March 2025...more

Upcoming Reminders for FinCEN Beneficial Ownership Information Reporting

Seward & Kissel LLP on 11/27/2024

The Financial Crimes Enforcement Network’s (“FinCEN’s”) beneficial ownership reporting rule, issued under the Corporate Transparency Act (the “CTA” and such rule, the “BOI Reporting Rule”) became effective as of January 1,...more

Updated Alert: FinCEN Imposes New Reporting Requirements on LLCs and other Entities

Seward & Kissel LLP on 10/18/2024

As a reminder to our clients and friends of the firm, the beneficial ownership reporting deadline is soon approaching. Applicable entities that were formed or registered to do business in the U.S. prior to this year, have...more

Treasury Subjects Investment Advisers to Anti-Money Laundering Requirements

Foley Hoag LLP on 9/10/2024

On August 28, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued its final rule requiring certain investment advisers to implement anti-money laundering (“AML”) compliance...more

FinCEN Proposes Rule To Strengthen US Anti-Money Laundering and Countering the Financing of Terrorism Programs

Skadden, Arps, Slate, Meagher & Flom LLP on 7/17/2024

The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has proposed a rule (the Proposed Rule) to implement certain aspects of the Anti-Money Laundering Act of 2020 (the AML Act), which updated the...more

FinCEN & the SEC: Will the Real RIA and ERA Customers Please Stand Up?

Morrison & Foerster LLP on 7/8/2024

On May 13, 2024, the U.S. Department of the Treasury’s (“Treasury”) Financial Crimes Enforcement Network (FinCEN) and the Securities and Exchange Commission (SEC) issued a joint Notice of Proposed Rulemaking (NPRM) that would...more

Investment Management Update - Q1 2024

Troutman Pepper Locke on 5/10/2024

This update covers legal developments and regulatory news for funds, their advisers, and industry participants for the quarter ended March 31. Rulemaking and Guidance: • SEC Adopts Reforms Relating to Investment Advisers...more

Recent Legal Developments Affecting Syndicated Real Estate Funds

Partridge Snow & Hahn LLP on 4/18/2024

Two recent developments may affect private funds, including syndicated real estate offerings. First, at the end of last summer the SEC adopted the Private Fund Adviser rules, regulations that cover certain aspects of...more

The Corporate Transparency Act’s Impact on Private Fund Managers: Immediate Planning Needed

Akin Gump Strauss Hauer & Feld LLP on 12/11/2023

Starting on January 1, 2024, entities that are organized in the United States or are registered to do business in the United States will generally be required to disclose to the Financial Crimes Enforcement Network (an...more

FINRA Reminds Broker-Dealers on Importance of Compliance with New AML Rules

The Volkov Law Group on 10/15/2021

The new Anti-Money Laundering laws and regulations continue to roll out with new risks, liabilities and compliance requirements. There is a coming AML enforcement storm, fueled by a new AML whistleblower program that will...more

Financial Services Weekly Roundup: The Supreme Court Strikes Back On Single Director Leadership Structures

Goodwin on 7/6/2020

In This Issue. The U.S. Supreme Court struck down the single director leadership structure of the Consumer Financial Protection Bureau (CFPB) in a ruling that could have far-reaching implications for the CFPB and other...more

Banking Regulators Release Statement on their BSA/AML Supervision Approach

Morgan Lewis on 8/8/2019

A working group composed of the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, the Office of the Comptroller of the Currency, and the US...more

CFTC ‘Clarifies’ Anti-Money Laundering Rule Obligations of Certain Introducing Brokers

Morgan Lewis on 8/6/2019

A recent interpretation by the CFTC (in consultation with FinCEN) of the customer identification program and beneficial ownership rules specifies that these rules do not apply to nontraditional introducing brokers, or...more

Investment Management Special Report - 2018-19 Compliance Developments & Calendar for Private Fund Advisers

Akin Gump Strauss Hauer & Feld LLP on 10/11/2018

Despite the new administration, the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) have both continued to make novel interpretations and to bring enforcement actions that break...more

Financial Services Weekly News - December 2016 #3

Goodwin on 12/22/2016

Editor's Note - The End of “Too Big to Fail”? On December 15, the Board of Governors of the Federal Reserve System (Federal Reserve Board) adopted a final rule to strengthen the ability of government authorities to...more

Orrick's Financial Industry Week in Review

Orrick, Herrington & Sutcliffe LLP on 7/30/2016

EBA Final Draft RTS on Assessment Methodology for Internal Ratings-Based Approach - The EBA has published final draft regulatory technical standards (RTS) on the specification of the assessment methodology for competent...more

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FinCEN › Investment Management

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