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A repository for the most well-read content on JD Supra at any given time, along with occasional roundups of popular content by specific topic. Also stop by for monthly recaps of hot articles for the previous... more +
A repository for the most well-read content on JD Supra at any given time, along with occasional roundups of popular content by specific topic. Also stop by for monthly recaps of hot articles for the previous thirty days. less -
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

Morrison & Foerster LLP

Top 5 SEC Enforcement Developments for May 2025

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On May 14, 2025, Deputy Enforcement Director Antonia Apps told those gathered at an anti‑money laundering conference in Washington, D.C. to expect a more measured approach from SEC Enforcement. That may include, she...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

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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

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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

K2 Integrity

Implementing FinCEN Final Rule Imposing Anti-Money Laundering Requirements On Investment Advisers

K2 Integrity on

On 28 August 2024, the Financial Crimes Enforcement Network (FinCEN) issued its Final Rulemaking to include certain investment advisers in the definition of a “financial institution” under the Bank Secrecy Act (BSA). The...more

Vedder Price

FinCEN Adopts Final Rule Extending Anti-Money Laundering Compliance Program Requirements to Certain Investment Advisers

Vedder Price on

On August 28, 2024, the Financial Crimes Enforcement Network (FinCEN) adopted a final rule (Final Rule) that adds registered investment advisers (RIAs) and exempt reporting advisers (ERAs) to the definition of “financial...more

Troutman Pepper Locke

FUNDamentals: Navigating FinCEN’s ‎New AML Regulations for Investment ‎Advisers

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On August 28, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a final rule (the “Rule”) that amends the definition of “financial institution” under the Bank Secrecy Act...more

Wilson Sonsini Goodrich & Rosati

FinCEN Finalizes Rule Requiring AML/CFT Programs for Registered Investment Advisers and Exempt Reporting Advisers

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On September 4, 2024, the U.S Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) published a final rule that expands the definition of “financial institution” to include Registered Investment Advisers...more

Morrison & Foerster LLP

FinCEN Expands its Reach with Final Rules for Investment Advisers and the Residential Real Estate Sector

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Key Takeaways - •FinCEN has issued two new final rules to significantly expand regulation around certain investment adviser and residential real estate sectors to combat illicit finance in these areas. These highly...more

Cooley LLP

FinCEN Issues Final Rule Requiring Investment Advisers to Establish Anti-Money Laundering Programs

Cooley LLP on

On August 28, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule that expressly includes certain investment advisers in the definition of a “financial institution”...more

Foley Hoag LLP

Treasury Subjects Investment Advisers to Anti-Money Laundering Requirements

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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

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

Lowenstein Sandler LLP

Investment Advisers Prepare: The BSA is Here

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On August 28, the United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (the “Final Rule”) subjecting certain registered investment advisers (RIAs) and exempt reporting...more

Cozen O'Connor

A Helpful Reminder for Broker-Dealers Subject to Examination by the SEC

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On June 5, 2024, the SEC's Division of Examinations (the Division) released a risk alert regarding the examination of broker-dealers. The alert acknowledges the diversity of the broker-dealer population in the marketplace...more

K&L Gates LLP

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

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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

Guidepost Solutions LLC

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

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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

Cooley LLP

SEC, FinCEN Propose to Mandate Customer Identification Programs for Registered Investment Advisers, Exempt Reporting Advisers

Cooley LLP on

On May 13, 2024, the US Securities and Exchange Commission (SEC) and the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) jointly issued a notice of proposed rulemaking that would require investment...more

Stinson LLP

SEC, FinCEN Propose Customer Identification Program Requirements for RIAs and ERAs

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On May 13, 2024, the Securities and Exchange Commission (SEC) and the Financial Crimes Enforcement Network (FinCEN) issued a joint notice of proposed rulemaking (proposed rule) that would impact how investment advisers handle...more

Jenner & Block

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

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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

Goodwin

FinCEN (and SEC) Propose New Customer Identification Program Rule With Minimal Expected Impact on Private Fund Sponsors

Goodwin on

On May 13, 2024, the Financial Crimes Enforcement Network (FinCEN), a bureau within the U.S. Treasury Department, and the Securities and Exchange Commission (SEC) proposed a joint rule (the Proposed Rule) with respect to a...more

Katten Muchin Rosenman LLP

Customer Identification Program Requirements for Investment Advisers

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On May 13, the Securities and Exchange Commission (SEC) and the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) jointly proposed to require that SEC-registered investment advisers (RIAs) and...more

WilmerHale

FinCEN Re-Proposes AML/CFT Requirements Covering Investment Advisers

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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

Pillsbury Winthrop Shaw Pittman LLP

FinCEN’s Proposed Rule to Regulate Investment Advisers: The Questions Industry Should Be Following

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FinCEN is focused on customer due diligence, and both the 2024 Investment Adviser Risk Assessment and proposed rule indicate that investment advisers will be expected to assess customer identity, business model, and sources...more

Troutman Pepper Locke

FUNDamentals: FinCEN [Re]Proposes Anti-Money Laundering Rules for Investment Advisers

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On February 13, 2024, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) proposed a new rule that would require federal investment advisers to add Bank Secrecy Act (“BSA”) type anti-money...more

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