Regulatory Alerts2024-02-13
Added
Anti-Money Laundering/Countering the Financing of Terrorism Program and Suspicious Activity Report Filing Requirements for Registered Investment Advisers and Exempt Reporting Advisers
The Financial Crimes Enforcement Network proposes to amend 31 CFR Parts 1010 and 1032 to include Registered Investment Advisers (RIAs) and Exempt Reporting Advisers (ERAs) in the definition of "financial institution" under the Bank Secrecy Act. This action requires these entities to implement anti-money laundering and countering the financing of terrorism programs, file Suspicious Activity Reports, and maintain records for fund transfers exceeding $10,000. The proposal also removes the existing requirement for investment advisers to file Form 8300 for cash receipts over $10,000 and delegates examination authority to the Securities and Exchange Commission. Written comments on this notice of proposed rulemaking must be submitted on or before April 15, 2024.