FinCEN and SEC Issue Proposed Customer Identification Program Requirements for Investment Advisers

In anticipation of the adoption of Financial Crimes Enforcement Network’s (FinCEN’s) proposed designation of certain investment advisers as “financial institutions” under the Banks Secrecy Act of 1970, FinCEN and the SEC recently issued a joint proposal (Proposed Rule) that would require those entities to implement customer identification programs. This article outlines the key features of the Proposed Rule and provides insights from industry experts about how it could impact fund managers’ overall AML compliance efforts.  See “Implications of the New E.U. AML Directive” (Jun. 5, 2024).

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