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FinCEN › Reporting Requirements › Investment Adviser

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... more +
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 -
ArentFox Schiff

Treasury Postpones Effective Date of Investment Adviser AML Rule

ArentFox Schiff on

On July 21, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a two-year postponement of the Anti-Money Laundering (AML)/Countering the Financing of Terrorism (CFT) Program and...more

Fenwick & West LLP

FinCEN Delays Investment Adviser AML/CFT Rule to January 2028: What Fund Managers Should Know

Fenwick & West LLP on

On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced that it intends to postpone the effective date of its 2024 investment advisor AML rule for registered investment...more

Wilson Sonsini Goodrich & Rosati

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

Wilson Sonsini Goodrich & Rosati on

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

Latham & Watkins LLP

FinCEN Postpones New AML Rule for Investment Advisers

Latham & Watkins LLP on

On July 21, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced that it intends to postpone the effective date of the final rule concerning the Anti-Money Laundering/Countering...more

Snell & Wilmer

Treasury and FinCEN Announce Delay of IA–AML Rule Implementation to January 1, 2028

Snell & Wilmer on

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

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

Seward & Kissel LLP

FinCEN Postpones Investment Adviser AML Requirements, Buying Time for Revisions

Seward & Kissel LLP on

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

Troutman Pepper Locke

FUNDamentals – FinCEN Delays Investment Adviser AML Rule Until 2028, Signals Revisions to Scope

Troutman Pepper Locke on

On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to delay the effective date of the final rule imposing anti-money laundering (AML) obligations on...more

Mayer Brown

BREAKING: FinCEN Postpones Effective Date of Investment Adviser AML Rule

Mayer Brown on

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

Dorsey & Whitney LLP

Investment Adviser Compliance with FinCEN’s AML/CFT Rule

Dorsey & Whitney LLP on

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

Lowenstein Sandler LLP

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

Lowenstein Sandler LLP on

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

Quarles & Brady LLP

Annual Update of Form ADV and Recent Regulatory Changes Affecting Advisers (UPDATED)

Quarles & Brady LLP on

As a reminder, each registered investment adviser must file an annual updating amendment to its Form ADV within 90 days of its fiscal year end. This means an adviser with a December 31 fiscal year end will be required to file...more

Carlton Fields

Deadline Approaches for RIAs to Adopt AML Programs CIP Requirements Remain in Limbo

Carlton Fields on

On August 28, 2024, the Financial Crimes Enforcement Network (FinCEN) adopted a final rule that subjects investment advisers to the anti-money laundering (AML) compliance provisions of the Bank Secrecy Act (BSA). For...more

K2 Integrity

Navigating the New Investment Adviser AML Mandate: What Steps Should Investment Advisers Be Taking Now?

K2 Integrity on

On 15 January 2025, K2 Integrity hosted a webinar that featured Justina Rousseau, senior managing director at K2 Integrity; Aseel Rabie, counsel at Debevoise & Plimpton LLP; and Sarah Runge, executive managing director at K2...more

Jones Day

Investment Advisers Subject to AML and SARs Requirements

Jones Day on

The Situation: The Financial Crimes Enforcement Network ("FinCEN") has adopted a rule that subjects certain investment advisers to anti-money laundering/countering the financing of terrorism program ("AML") requirements...more

Ballard Spahr LLP

FinCEN Finalizes Rule Subjecting Investment Advisers to AML/CFT Regulations

Ballard Spahr LLP on

Following up on its Notice of Proposed Rulemaking (“NPR”), which we discussed back in March, the Financial Crimes Enforcement Network (FinCEN) released on August 28th a final rule extending Anti-Money Laundering/Countering...more

Foley Hoag LLP

Treasury Subjects Investment Advisers to Anti-Money Laundering Requirements

Foley Hoag LLP on

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

Eversheds Sutherland (US) LLP

FinCEN adopts investment adviser AML rules

Eversheds Sutherland (US) LLP on

The Financial Crimes Enforcement Network (FinCEN) adopted a final rule that adds most federal Registered Investment Advisers (RIAs) and Exempt Reporting Advisers (ERAs) to the definition of “financial institution” under the...more

Foley Hoag LLP

The Corporate Transparency Act: Impact on Private Fund Managers

Foley Hoag LLP on

Private fund managers are reminded that the Corporate Transparency Act (CTA) may trigger reporting obligations to the Department of the Treasury’s Financial Crimes Enforcement Network for private fund managers and the private...more

White & Case LLP

FinCEN and SEC Move Closer to New AML Requirements for Investment Advisers & ERAs

White & Case LLP on

On May 13, 2024, FinCEN and the SEC jointly proposed a new rule that would require SEC-registered investment advisers and exempt reporting advisers to maintain written customer identification programs (CIPs). The new rule...more

Jenner & Block

Client Alert: A Second Wave: FinCEN and SEC Further Extend Investment Advisers’ AML Obligations with New CIP Requirements

Jenner & Block on

In a sequel to FinCEN’s proposal earlier this year to extend anti-money laundering and Bank Secrecy Act regulations to investment advisers (AML/BSA Proposal), on May 13, 2024, FinCEN and the SEC jointly issued a new Notice of...more

K2 Integrity

[Webinar] AML/CFT Rules for Investment Advisers - June 12th, 9:30 am PT

K2 Integrity on

On 13 February 2024, the Financial Crimes Enforcement Network (FinCEN) issued a groundbreaking Notice of Proposed Rulemaking (NPRM) to combat illicit finance and national security threats in the investment adviser sector. The...more

WilmerHale

FinCEN Re-Proposes AML/CFT Requirements Covering Investment Advisers

WilmerHale on

On February 15, 2024, the U.S. Department of the Treasury’s (Treasury) Financial Crimes Enforcement Network (FinCEN) issued a long-anticipated Notice of Proposed Rulemaking (NPRM) to impose comprehensive anti-money laundering...more

Bilzin Sumberg

U.S. Transparency Updates

Bilzin Sumberg on

The United States has started with a bang for 2024 with respect to transparency initiatives. The initiatives affect real estate, financial and business sectors. This alert provides a brief overview of the developments in...more

Jenner & Block

Client Alert: Unfinished Business: Investment Advisers Are Potentially Back on the Hook for Anti-Money-Laundering and...

Jenner & Block on

In its latest attempt, the U.S. Department of Treasury, Financial Crimes Enforcement Network (“FinCEN”), will require certain investment advisers to implement compliance measures to detect and report suspected money...more

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