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K&L Gates LLP

United States: AML Reprieve for Investment Advisers

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On July 21, 2025, the Financial Crimes Enforcement Network (FinCEN) announced that it is delaying the effective date of the investment adviser anti-money laundering rule (IA AML Rule) for two years from 1 January 2026 to 1...more

Morrison & Foerster LLP

FinCEN Postpones Effective Date of AML/CFT Rule for Investment Advisers

On July 21, 2025, the U.S. Department of the Treasury’s (“Treasury”) Financial Crimes Enforcement Network (FinCEN) announced it will delay the effective date of the final rule establishing anti-money laundering/countering the...more

Mayer Brown

BREAKING: FinCEN Postpones Effective Date of Investment Adviser AML Rule

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Earlier yesterday, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to postpone the effective date of the final rule establishing Anti-Money Laundering/Countering the...more

Dorsey & Whitney LLP

Investment Adviser Compliance with FinCEN’s AML/CFT Rule

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On August 28, 2024, Financial Crimes Enforcement Network (FinCEN) issued a final rule (the “Final Rule”) that imposes comprehensive anti-money laundering and countering the financing of terrorism (“AML/CFT”) requirements on...more

Ropes & Gray LLP

Navigating the Complexities of ETF Share Class Integration: Key Operational Challenges and Industry Insights

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One of the most talked about topics in asset management is the possibility of offering Mutual Fund and ETF Classes in the same Fund. For fund sponsors and service providers looking to offer this service, there are significant...more

Ropes & Gray LLP

Ropes & Gray’s Investment Management Update April – June 2025

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Since our prior IM Update, in separate Alerts, we covered (i) the SEC’s decision to remove from its regulatory agenda proposed rulemakings relevant to the investment management industry, (ii) Ropes & Gray’s updated and...more

Lowenstein Sandler LLP

The BSA’s Expansion & How Investment Advisers Can Leverage Existing AML Compliance Programs in the Cayman Islands To Comply With...

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On Aug. 28, 2024, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule (the Final Rule) extending the scope of the Bank Secrecy Act (BSA) and its amendments by requiring certain...more

Foley Hoag LLP

SEC Extends Compliance Date for Form PF Amendments to October 1, 2025

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On June 11, 2025, the Securities and Exchange Commission (“SEC”) voted to extend the compliance date for the amendments to Form PF that were adopted on February 8, 2024. The compliance date for these amendments, which was...more

Seward & Kissel LLP

Extension of Form PF Amendments Compliance Date

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On June 11th, 2025, the Securities and Exchange Commission (the “SEC”), together with the U.S. Commodity Futures Trading Commission (the “CFTC”) further extended the compliance date for the amendments to Form PF (the “Form PF...more

Proskauer - Regulatory & Compliance

SEC Further Extends Form PF Compliance Date and Signals Broader Reconsideration

On June 11, 2025, the Securities and Exchange Commission (“SEC”) voted to extend the compliance date for the most recently adopted amendments to Form PF by approximately four months, to October 1, 2025....more

Procopio, Cory, Hargreaves & Savitch LLP

Understanding FinCEN’s New AML/CFT Rule for Investment Advisers

What You Need to Know Before January 1, 2026 - Certain registered investment advisers (RIAs) and Exempt Reporting Advisors (ERAs) will face new federal compliance and filing requirements in the new year. Starting January 1,...more

Seward & Kissel LLP

May 30 Deadline for BE-10 Reports

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The BE-10 is the quinquennial Benchmark Survey of U.S. Direct Investment Abroad that is conducted by the U.S. Bureau of Economic Analysis (the “BEA”) to obtain data on the financial structure and operations of U.S. parent...more

Carey Olsen

British Virgin Islands investment funds - Spring 2025 update

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Our investment funds team outline the latest developments within the investment funds market in the British Virgin Islands ("BVI"), including the funds statistics from the British Virgin Islands Financial Services Commission...more

Seward & Kissel LLP

SEC Issues Industry Letter Allowing Insurance Companies to File Certain Financial Statements

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Who may be interested: Insurance Companies - Quick Take: In an Industry Letter, the SEC’s Division of Investment Management stated that insurance companies may file financial statements prepared in accordance with...more

Paul Hastings LLP

SEC Updates Marketing Rule and Form PF FAQs in Short Succession

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On March 19, the SEC issued updates to its FAQs regarding compliance with Rule 206(4)-1 of the Advisers Act (the Marketing Rule) addressing (i) when gross and net performance are required for certain “extracted” performance,...more

A&O Shearman

ESMA guidelines on suitability requirements and format of the periodic statement for portfolio management activities under MiCAR

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Official translations of the guidelines on certain aspects of the suitability requirements and format of the periodic statement for portfolio management activities under the EU Markets in Crypto Assets Regulation (MiCAR) have...more

DLA Piper

SEC Clarifies When Gross-Only Performance May Be Permissible

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The US Securities and Exchange Commission staff (Staff) has issued revised guidance regarding the application of Rule 206(4)-1 under the Investment Advisers Act of 1940, as amended (Marketing Rule), providing flexibility for...more

DLA Piper

Institutional Investor Newsletter: Q1 2025

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Former President Joe Biden issued Executive Order (EO) 14105, “Executive Order on Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern” on August 9, 2023. More...more

DLA Piper

Chile: Comisión Para el Mercado Financiero Crea el Manual de Sistemas de Información de Fondos

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El 28 de febrero de 2025, la Comisión para el Mercado Financiero (CMF) emitió la Norma de Carácter General N°532 (NCG 532), que crea el Manual de Sistemas de Información de Fondos y establece la forma, periodicidad y medio a...more

DLA Piper

Chile: Financial Market Commission creates its Fund Information Systems Manual

DLA Piper on

On February 28, 2025, Chile’s Financial Market Commission (CMF, for its Spanish translation) issued General Rule No. 532 (NCG 532), which creates a Fund Information Systems Manual and establishes the form, frequency, and...more

Foley Hoag LLP

SEC Announces One Year Delay in Filing Obligations under Rule 13f-2 and Corresponding Form SHO

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On October 13, 2023, the Securities and Exchange Commission (the “SEC”) adopted Rule 13f-2 and related Form SHO pursuant to the Securities Exchange Act of 1934. Rule 13f-2 requires that any party meeting the definition of...more

Ropes & Gray LLP

Ropes & Gray’s Investment Management Update December 2024 – January 2025

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On February 7, 2025, the SEC issued an order postponing compliance requirements with Rule 13f-2 under the Securities Exchange Act and reporting requirements on Form SHO. As a result, initial Form SHO reports from...more

Mayer Brown Free Writings + Perspectives

SEC Grants Temporary Exemption from Rule 13f-2 and Form SHO Compliance

On February 7, 2025, the US Securities and Exchange Commission (SEC) provided a temporary exemption from compliance with Rule 13f-2 under the Securities Exchange Act and the associated Form SHO reporting. Originally, the...more

Katten Muchin Rosenman LLP

SEC Issues Updated "Names Rule" FAQ

On January 8, 2025, the Securities and Exchange Commission's (SEC) Division of Investment Management (Division) issued responses to certain frequently asked questions (FAQ) to the SEC's 2023 adoption of amendments...more

Carlton Fields

Amendments to N-PORT May Be OUT-Ported New SEC Reporting Requirements Already Under Challenge

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Gary Gensler’s tenure as SEC chair can be remembered for an impressive number of rule proposals, many of which encountered vehement industry opposition or were challenged in court, struck down, or stayed....more

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