FinCEN Proposes Anti-Money Laundering and Suspicious Reporting Rules for Registered Investment Advisers

Morrison & Foerster LLP

On August 25, 2015, the US Treasury Department’s Financial Crimes Enforcement Network (FinCEN) proposed rules that would require registered investment advisers to adopt anti-money laundering (AML) programs and report suspicious activity to FinCEN.

FinCEN said that it proposed the rules to regulate investment advisers that may be at risk of attempts by money launderers or terrorist financers to access the US financial institutions that currently are not required to maintain AML programs or file suspicious activity reports (SARs). The rules would apply to investment advisers registered with the Securities and Exchange Commission (SEC) or required to be registered with the SEC. They would not apply to investment advisers exempt from registration.

Originally published in The Investment Lawyer on November 5, 2015.

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