AML Requirements Proposed for SEC Registered Advisers

Morgan Lewis
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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 additional reporting requirements on investment advisers registered with the US Securities and Exchange Commission (SEC).

FinCEN’s proposal would require registered investment advisers to have anti-money laundering programs in place, file suspicious activity reports, and comply with additional reporting requirements. The proposal furthers the United States’ efforts to comply with international AML standards and recommendations.

Please see full White Paper below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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