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Know Your Customers Suspicious Activity Reports (SARs) Investment Adviser

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

BCLP

Continuing AML regulatory issue focus: A look at a recent SEC enforcement case, the SEC’s response to Petition for Certiorari, and...

BCLP on

Garcia Case Highlights Necessity of Knowing Your Customer and Listening to Internal Fraud Watchdogs. The SEC’s recent Order against a broker-dealer (the “Firm”) imposed a $750,000 financial penalty for the Firm’s failure...more

Skadden, Arps, Slate, Meagher & Flom LLP

"A Long Time Coming: FinCEN Proposes AML Program and SAR Requirements for Investment Advisers"

On August 25, 2015, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a notice of proposed rulemaking (“NPRM”) that would impose certain anti-money laundering (“AML”) requirements on...more

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