News & Analysis as of

Bank Secrecy Act › Investment Advisers Act of 1940

The Bank Secrecy Act is a United States federal statute enacted in 1970 to detect and prevent money laundering within financial institutions. The BSA requires financial institutions to keep records and provide... more +
The Bank Secrecy Act is a United States federal statute enacted in 1970 to detect and prevent money laundering within financial institutions. The BSA requires financial institutions to keep records and provide documentation to authorities for single transactions of more than $10,000 and report other suspicious account activity that could signify money laundering or other financial crimes. less -
King & Spalding

Request for Comments on FinCEN and SEC rule on CIP

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The SEC and FinCEN Request Comments on their Proposed Rule on Customer Identification Programs for Registered Investment Advisers and Exempt Reporting Advisers - The Securities and Exchange Commission (“SEC”) and the...more

Locke Lord LLP

FUNDamentals: Is the Joint FinCEN and SEC Proposal for Investment Adviser Customer Identification Program DoA?

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On May 13, 2024, the U.S. Securities and Exchange Commission’s Division of Investment Management (“SEC”) and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a joint proposal...more

Pillsbury Winthrop Shaw Pittman LLP

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

Pillsbury Winthrop Shaw Pittman LLP on

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

King & Spalding

FinCEN Proposes Rule to Extend Bank Secrecy Act Obligations to Certain Investment Advisers

King & Spalding on

The Proposed Rule Would Subject Certain Investment Advisers to a Broad Range of AML/CFT Obligations and Represents a Significant Development for the Sector - Regulators have long considered the lack of anti-money...more

McGuireWoods LLP

Bank Secrecy Act’s Anti-Money Laundering and Counter Terrorism Financing Requirements to Apply to Investment Advisers

McGuireWoods LLP on

The Bank Secrecy Act (“BSA”) establishes program, recordkeeping, and reporting requirements for certain financial institutions to combat and detect money laundering, terrorist financing, and other illicit activities. On...more

Goodwin

Supreme Court Decision Empowers President Biden to Replace Director of FHFA

Goodwin on

In This Issue. In a move that gives him the opportunity to put his stamp on housing policy and the potential overhaul of Fannie Mae and Freddie Mac, President Biden replaced the Director of the Federal Housing Finance Agency...more

Blank Rome LLP

Regulatory Update and Recent SEC Enforcement Actions

Blank Rome LLP on

On June 2, 2016, the SEC announced that it hired Christopher R. Hetner, a cybersecurity expert, as the Senior Adviser to the Chair for Cybersecurity Policy. The hire is indicative of the SEC’s focus on cybersecurity measures...more

Locke Lord LLP

Top 10 Financial Institution Considerations for 2016: #2 – Bank Secrecy Act/Anti-Money Laundering and OFAC Compliance

Locke Lord LLP on

In our initial article announcing our top 10 considerations for financial institutions in 2016, our second consideration was Bank Secrecy Act/anti-money laundering (BSA/AML) and OFAC compliance in 2016. Compliance with the...more

Ballard Spahr LLP

Investment Management Update - October 2015

Ballard Spahr LLP on

Below is a summary of recent investment management developments that affect registered investment companies, private equity funds, hedge funds, investment advisers, and others in the investment management industry. Schwab...more

Morgan Lewis

AML Requirements Proposed for SEC Registered Advisers

Morgan Lewis on

On August 25, the Financial Crimes Enforcement Network (FinCEN), a bureau of the US Department of the Treasury (Treasury), published a notice of proposed rulemaking (NPRM) to impose anti-money laundering (AML) programs and...more

King & Spalding

FinCEN Proposes New Anti-Money Laundering Rule For Investment Advisers

King & Spalding on

On August 25, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) released a Notice of Proposed Rulemaking (NPRM), which would impose anti-money laundering (AML), suspicious activity reporting,...more

Morrison & Foerster LLP

FinCEN Proposes Anti-Money Laundering Rules for Registered Advisers

Morrison & Foerster LLP on

The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) on August 25, 2015 proposed rules to require SEC- registered investment advisers to adopt and maintain anti-money laundering (AML) programs and to...more

Goodwin

FinCEN Proposes AML Program Rule for Investment Advisers

Goodwin on

The Financial Crimes Enforcement Network (FinCEN) has issued a proposed rule that would subject certain investment advisers to AML requirements under the Bank Secrecy Act (the BSA). In proposing the rule, FinCEN cited...more

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