FinCEN’s Proposed Anti-Money Laundering Compliance Requirements for Investment Advisers

How to Prepare Now

In 2015, the Financial Crimes Enforcement Network (FinCEN) proposed a rule requiring investment advisers registered with the U.S. Securities and Exchange Commission (SEC) to establish anti-money laundering (AML) programs and file suspicious activity reports (SARs).1 The proposed rule will affect over 11,000 investment advisers controlling over $62 trillion in assets, and will authorize the SEC to conduct compliance examinations on registered investment advisers. Though FinCEN’s 2015 rule is a proposal only, there is little chance that FinCEN will not finalize the rule.

Navigant’s latest client alert FinCEN’s Proposed Anti-Money Laundering Compliance Requirements for Investment Advisers, discusses FinCEN’s latest proposed rule requiring investment advisers registered with the SEC to establish AML programs and file SARs. This article also discusses measures that investment managers can take to prepare for the proposed rulemaking.

 

1. 31 CFR Chapter X. RIN: 1506-AB10. See: http://www.fincen.gov/statutes_regs/frn/pdf/1506-AB10_FinCEN_IA_NPRM.pdf.

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