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Sep 08, 2015

Financial Crimes Enforcement Network: Anti-Money Laundering Program and Suspicious Activity Report Filing Requirements for Registered Investment Advisers

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On August 25, 2015, the U.S. Financial Crimes Enforcement Network (“FinCEN”), the bureau of the Department of the Treasury with principal responsibility for implementing anti-money laundering rules and regulations, issued a notice of proposed rulemaking aimed to prescribe minimum standards for anti-money laundering programs (“AML”) for investment advisers registered, or required to be registered, with the U.S. Securities and Exchange Commission (“SEC”) and to require such investment advisers to report suspicious activity to FinCEN pursuant to the Bank Secrecy Act (“BSA”). Financial institutions other than investment advisers are already subject to BSA and self-regulatory organization rules requiring anti-money laundering programs.

View full memo, Financial Crimes Enforcement Network

Authors and Contributors

John Adams

Partner

Investment Funds

+44 20 7655 5740

+44 20 7655 5740

London

Lorna Xin Chen

Partner

Investment Funds

+852 2978 8001

+852 2978 8001

Hong Kong

John (Sean) Finley

Partner

Investment Funds

+1 212 848 4346

+1 212 848 4346

New York

Laura Friedrich

Partner

Investment Funds

+1 212 848 7411

+1 212 848 7411

New York

Nathan Greene

Partner

Investment Funds

+1 212 848 4668

+1 212 848 4668

New York

Thomas Majewski

Counsel

Investment Funds

+1 212 848 7182

+1 212 848 7182

New York

Jennifer D. Morton

Counsel

Financial Institutions Advisory & Financial Regulatory

+1 212 848 5187

+1 212 848 5187

New York

John Reiss

Counsel

Investment Funds

+1 212 848 7669

+1 212 848 7669

New York

Russell Sacks

Partner

Financial Institutions Advisory & Financial Regulatory

+1 212 848 7585

+1 212 848 7585

New York

Reena Agrawal Sahni

Partner

Financial Institutions Advisory & Financial Regulatory

+1 212 848 7324

+1 212 848 7324

New York

Paul Schreiber

Of Counsel

Investment Funds

+1 212 848 8920

+1 212 848 8920

New York