News & Analysis as of

Investment Adviser Anti-Money Laundering Investment

Haynes Boone

FinCEN Announces Intention to Postpone Effective Date of Anti-Money Laundering Rule for Registered Investment Advisers and Exempt...

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FinCEN will work through the rulemaking process to formally extend the IA AML Rule effective date and intends to provide the IA sector with regulatory certainty by issuing appropriate exemptive relief delaying the effective...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

DLA Piper

SEC Enforcement Actions Highlight Anti-Money Laundering Reporting Focus for Financial Gatekeepers

DLA Piper on

The Securities and Exchange Commission (SEC) announced on November 22, 2024, that three broker-dealers have agreed to settle charges for filing suspicious activity reports (SARs) that failed to include important, required...more

Troutman Pepper Locke

The SEC’s Division of Examinations Announces 2025 Priorities

Troutman Pepper Locke on

On October 21, the Securities and Exchange Commission’s (SEC) Division of Examinations announced its 2025 examination priorities (2025 guidance) for registered investment advisers and investment companies, broker-dealers,...more

Guidepost Solutions LLC

Investment Advisers and Generative AI

Start Planning Now to Reduce Your Increased Money Laundering, Sanctions, and Conflicts of Interest Risks The introduction and use of generative artificial intelligence (GenAI) and predictive data analytics (PDAs) by...more

K2 Integrity

Proposed Rule to Impose Anti-Money Laundering Requirements on Investment Advisers

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

Skadden, Arps, Slate, Meagher & Flom LLP

Investment Management Update - November 2023

...SEC Adopts Amendments to Fund Names Rule - On September 20, 2023, the U.S. Securities and Exchange Commission (SEC) adopted amendments to Rule 35d-1 under the Investment Company Act of 1940 (the Fund Names Rule) as well...more

Morrison & Foerster LLP

Top 5 SEC Developments for July 2023

In order to provide an overview for busy in-house counsel and compliance professionals, we summarize below some of the most important SEC enforcement developments from the past month, with links to primary resources. This...more

Proskauer Rose LLP

Shining a Light on the Corporate Transparency Act: FinCEN’s Rules for Beneficial Ownership Reporting

Proskauer Rose LLP on

On January 1, 2021, Congress enacted the Corporate Transparency Act (the “CTA”) as part of the Anti-Money Laundering Act of 2020 in the National Defense Authorization Act for Fiscal Year 2021. Congress passed the CTA to...more

Snell & Wilmer

SEC Action Could Have Rippling Effects on Future of Cryptocurrency

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Many investors, traditional and progressive, are looking hard at cryptocurrency investments as a way to diversify their portfolios. However, there are still multiple known “unknowns” about this new market, including the...more

A&O Shearman

Motion To Dismiss Filed In Eastern District Of New York Case Could Provide Opportunity For Clarity On Scope Of FCPA's "Internal...

A&O Shearman on

On November 20, 2020, lawyers for a former investment banker, indicted in the United States District Court for the Eastern District of New York for his alleged role in the 1MDB matter, filed a Motion to Dismiss (“MTD”) the...more

Ballard Spahr LLP

Investment Management Update - October 2015

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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

Troutman Pepper

FinCEN's Recently Proposed AML Rule: A Road Map for SEC-Registered Investment Advisers

Troutman Pepper on

The U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (the Proposed Rule) on September 1, 2015 that would impose anti-money laundering (AML) requirements for investment...more

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