Financial Crimes Enforcement Network: Anti-Money Laundering Program and Suspicious Activity Report Filing Requirements for Registered Investment Advisers

On August 25, 2015, the U.S. Financial Crimes Enforcement Network (“FinCEN”), the bureau of the Department of the Treasury with principal responsibility for implementing anti-money laundering rules and regulations, issued a notice of proposed rulemaking aimed to prescribe minimum standards for anti-money laundering programs (“AML”) for investment advisers registered, or required to be registered, with the U.S. Securities and Exchange Commission (“SEC”) and to require such investment advisers to report suspicious activity to FinCEN pursuant to the Bank Secrecy Act (“BSA”). Financial institutions other than investment advisers are already subject to BSA and self-regulatory organization rules requiring anti-money laundering programs.