Regulatory Alerts2024-08-28
Anti-Money Laundering and Suspicious Activity Report Requirements for Investment Advisers
The Financial Crimes Enforcement Network issued a final rule adding certain SEC-registered and exempt reporting investment advisers to the definition of financial institution under the Bank Secrecy Act. This regulation mandates that these advisers establish minimum anti-money laundering and countering the financing of terrorism programs and file suspicious activity reports with FinCEN. The rule becomes effective on January 1, 2026, and excludes state-registered advisers, foreign private advisers, and family offices from its scope.
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