News & Analysis as of

Investment Adviser Compliance Anti-Money Laundering

Alston & Bird

FinCEN Delays Enforcement of Investment Adviser AML/CFT Rule

Alston & Bird on

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

BCLP

FINCEN Postpones AML/CFT Rules for Investment Advisers Until 2028 and Revisits Scope of Such Rules

BCLP on

FinCEN’s announcement clearly reflected its sensitivity to industry concerns. It acknowledged that AML/CFT Rules “must be effectively tailored to the diverse business models and risk profiles of the investment adviser...more

King & Spalding

FinCEN Announces It Will Provide Two-Year Extension of the AML Rule Compliance Date for Registered Investment Advisers and Exempt...

King & Spalding on

Registered Investment Advisers (RIAs) and Exempt Reporting Advisers (ERAs) were less than six months away from the requirement to implement an anti-money laundering and countering the financing of terrorism (AML/CFT) program...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

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

Eversheds Sutherland (US) LLP

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

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

Proskauer Rose LLP

Treasury to Delay Investment Adviser AML Rule to 2028, Announces Intent to Reconsider AML and CIP Rules

Proskauer Rose LLP on

On July 21, 2025, the Department of the Treasury announced a two-year postponement of the much-anticipated anti-money laundering (AML) rule, adopted by Treasury’s Financial Crimes Enforcement Network (FinCEN) in 2024,...more

Lowenstein Sandler LLP

Bank Secrecy Act Postponed for Investment Advisers and Exempt Reporting Advisers

Lowenstein Sandler LLP on

On July 21, the United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intent to postpone compliance with new regulatory requirements imposing certain anti-money laundering...more

SEC Compliance Consultants, Inc. (SEC³)

Predictions for 2025: What Private Fund Advisers Can Expect from SEC Examinations

There has been a lot of conjecture that the SEC may become friendlier to registrants because of the new administration. Given the SEC’s mandate to protect the investing public, however, we do not expect SEC examiners to...more

White & Case LLP

SEC Charges Investment Adviser - Signaling Importance of Accurate Disclosure of AML Procedures

White & Case LLP on

The U.S. Securities & Exchange Commission ("SEC") recently announced settled charges against an investment adviser for misrepresentations regarding its anti-money laundering ("AML") procedures and compliance failures. As we...more

ArentFox Schiff

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

ArentFox Schiff on

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

Goodwin

AML/CTF Asset Due Diligence Obligations: CSSF Provides Clarifications in an initial Q&A

Goodwin on

On 13 December 2024, the Commission de Surveillance du Secteur Financier (CSSF) published the first FAQ to assist professionals in the investment sector supervised, authorised, or registered by the CSSF in complying with...more

Cozen O'Connor

Summarizing the SEC’s 2025 Examination Priorities Report, Part 2

Cozen O'Connor on

In the second part of this legal update series, we summarize the key takeaways from the Division of Examinations’ (Division) 2025 priorities report released on October 21, 2024. The Division remains focused on mainstays like...more

ArentFox Schiff

FinCEN Releases Final Anti-Money Laundering Rule for Investment Advisers

ArentFox Schiff on

On August 28, the Financial Crimes Enforcement Network (FinCEN) issued a final rule establishing anti-money laundering and countering the financing of terrorism (AML/CFT) compliance obligations for US Securities and Exchange...more

BCLP

FinCEN Adopts AML/CFT Rules for Investment Advisers with Few Changes from Proposed Rules

BCLP on

On August 28, 2024, the Financial Crimes Enforcement Network (“FinCEN”) adopted final rules (“Rules”) applicable to investment advisers with relatively few changes from the rules as proposed....more

Goodwin

FinCEN Adopts Final AML Program Rule for Investment Advisers

Goodwin on

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) adopted a final rule (the Final Rule) on August 28 that will treat certain investment advisers and exempt reporting advisers as financial...more

King & Spalding

FinCEN Issues Final Rule Expanding Anti-Money Laundering/ Countering the Financing of Terrorism Requirements for Investment...

King & Spalding on

On September 4, 2024, the Financial Crimes Enforcement Network (“FinCEN”), U.S. Department of Treasury, published a final rule (the “Final Rule”) expanding the definition of “financial institution” under the Bank Secrecy Act...more

Alston & Bird

Investment Advisers Face New AML/CFT Compliance Obligations from FinCEN

Alston & Bird on

Our Financial Services, Investment Funds, and White Collar, Government & Internal Investigations Teams break down the latest Financial Crimes Enforcement Network (FinCEN) rule investment advisers must prepare for....more

DLA Piper

National Security Risks Headline New AML Requirements for Investment Advisers – and More to Come?

DLA Piper on

Last week, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a widely anticipated final rule to police the estimated $125 trillion-plus investment adviser market. The new rule extends...more

K&L Gates LLP

AML Update: SEC and FinCEN Propose Anti-Money Laundering and Customer Identification Programs for Investment Advisers

K&L Gates LLP on

Introduction - On 13 May 2024, the Securities and Exchange Commission (SEC) and the US Department of Treasury’s (DoT) Financial Crimes Enforcement Network (FinCEN) jointly proposed rulemaking to implement Section 326 of the...more

Mayer Brown Free Writings + Perspectives

SEC and FinCEN Propose Customer Identification Program Requirements for Certain Investment Advisers

I. INTRODUCTION - On May 13, 2024, the US Securities and Exchange Commission (“SEC”) and the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a joint notice of proposed rulemaking (the...more

Guidepost Solutions LLC

Money Laundering, Terrorist Financing, and Investment Advisors – Yes, Financial Crime is Borderless and Legal Entity-Agnostic

There is a growing acknowledgement that money laundering and terrorist financing is borderless and legal entity-agnostic, just as it is already known that cybercriminals and the means to commit cybercrimes continuously attack...more

Royer Cooper Cohen Braunfeld LLC

SEC & FinCEN Propose Customer Identification Program Requirements

A press release was recently issued describing a significant joint proposal by the Securities and Exchange Commission (SEC) and the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN). The proposal...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

Morrison & Foerster LLP

Investment Adviser Compliance Index - March 2024

The Investment Advisers Act of 1940 (the “Advisers Act”) is a relatively compact statute, and for many years the Securities and Exchange Commission (SEC) adopted relatively few regulations specifically targeting Advisers Act...more

51 Results
 / 
View per page
Page: of 3

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide