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Rulemaking Process Compliance Investment Adviser

BCLP

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

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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

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

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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

Katten Muchin Rosenman LLP

FINRA Proposes and Seeks Comment on Simplified Rules for Outside Business Activities and Private Securities Transactions

On Friday, March 14, in Regulatory Notice 25-05, the Financial Industry Regulatory Authority (FINRA) proposed a new rule to address when registered individuals engage in activities away from their member firms and when...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

Morrison & Foerster LLP

Extended Compliance Date for Recent Form PF Amendments

The new year always marks the start of a busy regulatory filing season for registered investment advisers, including investment advisers that file Form PF (“Form PF Filers”). This year could be especially challenging since,...more

Proskauer Rose LLP

SEC and CFTC Extend Compliance Date for Form PF Amendments

Proskauer Rose LLP on

On January 29, 2025, the Securities and Exchange Commission (“SEC”) and Commodity Futures Trading Commission (together, the “Agencies”) jointly announced that the compliance date for the new Form PF would be extended by three...more

Seward & Kissel LLP

SEC Staff Issues New Names Rule FAQs

Seward & Kissel LLP on

Who may be interested: Registered Investment Companies; Compliance Officers - Quick Take: The staff of the Division of Investment Management (Staff) of the SEC recently issued responses to frequently asked questions (FAQs)...more

Katten Muchin Rosenman LLP

The SEC Lives On Under New Leadership — What to Expect

President-elect Donald J. Trump nominated Paul Atkins to succeed Gary Gensler as Securities and Exchange Commission (SEC or Commission) Chair on December 4. Atkins was an SEC staff attorney under SEC Chairs Richard Breeden...more

Proskauer - The Capital Commitment

Lawsuit Challenges Private Fund Adviser Rules

On Friday, September 1, 2023, a lawsuit was filed with the federal Court of Appeals in the Fifth Circuit challenging the validity and enforceability of the recently adopted Private Fund Adviser Rules under the Investment...more

Davis Wright Tremaine LLP

Broker Dealer Regulatory Digest - August 2023

The following newsletter provides a roundup summarizing enforcement actions, guidance, rulemakings, and other public statements taken by a federal and/or state financial services regulatory agency, specifically focusing on:...more

Goodwin

FinCEN Finalizes Rule Implementing beneficial Ownership Reporting Requirements Under the CTA

Goodwin on

Regulatory Developments - FinCEN Finalizes Rule Implementing Beneficial Ownership Reporting Requirements Under the Corporate Transparency Act - On September 29, FinCEN issued a final rule under the CTA requiring each...more

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