2024-08-28 | PDF Only

Added

FinCEN Final Rule on Investment Adviser AML/CFT Requirements

The rule adds registered investment advisers (RIAs) and exempt reporting advisers (ERAs) to the definition of financial institution under the Bank Secrecy Act, requiring them to implement risk-based anti-money laundering and countering the financing of terrorism programs, file Suspicious Activity Reports, and maintain specific records. Covered entities include RIAs registered with the SEC and ERAs, excluding mid-sized advisers, multi-state advisers, pension consultants, and those with no reportable assets under management. FinCEN delegates examination authority for these requirements to the Securities and Exchange Commission, and the compliance date is set for January 1, 2026.

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