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Money Laundering Bank Secrecy Act Investment Adviser

Ballard Spahr LLP

FinCEN Finalizes Rule Subjecting Investment Advisers to AML/CFT Regulations

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Following up on its Notice of Proposed Rulemaking (“NPR”), which we discussed back in March, the Financial Crimes Enforcement Network (FinCEN) released on August 28th a final rule extending Anti-Money Laundering/Countering...more

ArentFox Schiff

SEC and FinCEN Propose New Rule: Mandatory Customer Verification for Investment Advisers in 2024

ArentFox Schiff on

On May 13, the US Securities and Exchange Commission (SEC) and the US Department of the Treasury’s (USDT) Financial Crimes Enforcement Network (FinCEN) jointly released a notice of proposed rulemaking (NPRM) which, if...more

Guidepost Solutions LLC

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

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

Woodruff Sawyer

Only You (Investment Advisers)! Can Prevent Money Laundering

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If you are an investment manager and you significantly and repeatedly outperform the market, your investors will lavish you with righteous praise and your firm will shower you with well-deserved riches....more

Seward & Kissel LLP

FinCEN Proposes New Rule to Subject Advisers to AML Requirements

Seward & Kissel LLP on

Who may be interested: Investment Advisers; Closed-End Funds; and Directors of Closed-End Funds - Quick Take: The U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) recently issued a notice of...more

Troutman Pepper

FinCEN Proposes New Investment Adviser AML Rule

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On February 1/3, the Financial Crimes Enforcement Network (FinCEN) proposed a new rule (the Proposed Rule), that, if adopted, would add certain investment advisers to the definition of “financial institution” under the Bank...more

Mayer Brown

Third Time’s the Charm? Anti-Money Laundering Compliance Requirements Proposed for Registered and Exempt Reporting Investment...

Mayer Brown on

On February 13, 2024, the Financial Crimes Enforcement Network (“FinCEN”) proposed anti-money laundering (“AML”) compliance obligations for certain investment advisers (the “Proposal”)....more

Troutman Pepper

FinCEN Proposes Extending AML/CFT Requirements to Certain Investment Advisors

Troutman Pepper on

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) recently announced a Notice of Proposed Rulemaking (NPRM) aimed at keeping bad actors from exploiting the U.S. financial system and assets...more

Sheppard Mullin Richter & Hampton LLP

Treasury Announces Renewed Push for Investment Adviser AML Rules in Q1 2024

The United States Department of the Treasury has announced that it is working to address what it perceives as money laundering risks associated with investment advisers. Specifically, the agency asserts that absent consistent...more

Ballard Spahr LLP

New FinCEN Director Addresses Key Topics in BSA/AML

Ballard Spahr LLP on

The new Director of FinCEN, Andrea Gacki, addressed several key topics on October 3, 2023 at the Association of Certified Anti-Money Laundering Specialists (“ACAMS”) conference in Las Vegas, Nevada. Specifically, Director...more

Ballard Spahr LLP

Investment Management Update - October 2015

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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

Baker Donelson

Advisers Charged with Cleansing Dirty Money from Industry

Baker Donelson on

On August 25, 2015, the Financial Crimes Enforcement Network (FinCEN) proposed an anti-money laundering rule applicable to SEC-registered investment advisers (RIAs). The proposed rule would require RIAs to establish...more

K&L Gates LLP

AML Update: The Rumors Are True – FinCEN Proposes Regulations That Will Require SEC Registered Investment Advisers to Adopt an AML...

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On September 1, 2015, the Financial Crimes Enforcement Network (“FinCEN”) published in the Federal Register long-rumored proposed regulations that will require Securities and Exchange Commission (“SEC”)-registered investment...more

BakerHostetler

AML and Investment Advisers: Understanding FinCEN's New Anti-Money Laundering Rules

BakerHostetler on

On August 25, 2015, the Financial Crimes Enforcement Network (FinCEN) proposed rulemaking that would require registered investment advisers, including certain hedge funds and asset managers, to establish anti-money laundering...more

Morrison & Foerster LLP

FinCEN Proposes Anti-Money Laundering Rules for Registered Advisers

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

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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

Stinson - Corporate & Securities Law Blog

FinCEN Proposes Extending Anti-Money Laundering Compliance Requirements to Investment Advisers

On Tuesday, the United States Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) proposed a rule that would require SEC-registered investment advisers, including private equity and hedge funds, to comply...more

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