FinCEN Proposes AML Requirements on Registered Investment Advisers (including Exempt Reporting Advisers)
By: Richard F. Kerr, Jennifer L. Klass, and Annabelle H. North
On 13 February 2024, the Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (NPRM) that would impose anti-money laundering (AML) and counter-terrorist financing (CFT) requirements on Securities and Exchange Commission-registered investment advisers (the SEC, and such investment advisers, RIAs) and exempt reporting advisers (ERAs). FinCEN previously made similar rule proposals in both 2003 and 2015, which were never finalized.
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