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FinCEN › Reporting Requirements › Investment Advisers Act of 1940

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 -
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

Akin Gump Strauss Hauer & Feld LLP

Update (2): The NY LLC Transparency Act and Corporate Transparency Act’s Impact on Private Fund Managers

Akin Gump Strauss Hauer & Feld LLP on

In the weeks since publishing our original alert, FinCEN released several frequently asked questions (FAQs) on the application of the Corporate Transparency Act (CTA). Private fund managers are likely to find two of these...more

Dinsmore & Shohl LLP

Private Investment Funds: Assess Your Structures and Prepare for Corporate Transparency Act Compliance

Dinsmore & Shohl LLP on

Beginning January 1, 2024, companies created or registered in the United States will have to report information about their ownership to the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of...more

Faegre Drinker Biddle & Reath LLP

Implications of the Corporate Transparency Act in the Investment Management Industry

Faegre Drinker Biddle & Reath LLP on

The Corporate Transparency Act, as we have previously reported1, is a new federal law designed to combat money laundering, tax evasion, and other illicit financial activities by requiring “reporting companies” to disclose...more

Davies Ward Phillips & Vineberg LLP

Preparing for the Corporate Transparency Act

Davies Ward Phillips & Vineberg LLP on

The beneficial ownership reporting requirements under the U.S. Corporate Transparency Act (the CTA) will go into effect on January 1, 2024. All entities formed or registered to do business in a U.S. state,1 other than certain...more

Morrison & Foerster LLP

FinCEN Proposes Anti-Money Laundering Rules for Registered Advisers

Morrison & Foerster LLP on

The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) on August 25, 2015 proposed rules to require SEC- registered investment advisers to adopt and maintain anti-money laundering (AML) programs and to...more

Goodwin

FinCEN Proposes AML Program Rule for Investment Advisers

Goodwin on

The Financial Crimes Enforcement Network (FinCEN) has issued a proposed rule that would subject certain investment advisers to AML requirements under the Bank Secrecy Act (the BSA). In proposing the rule, FinCEN cited...more

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