FinCEN Proposes AML Requirements for Registered Investment Advisers

August 26, 2015

The Financial Crimes Enforcement Network ("FinCEN") issued proposed rules that would require registered investment advisers to develop and implement a written anti-money laundering ("AML") program reasonably designed to prevent the adviser from being used for money laundering and the financing of terrorist activities and to achieve and monitor compliance with applicable provisions of the Bank Secrecy Act. Under the proposals, the AML program would be required to be approved in writing by the adviser's board of directors or other persons having similar functions.

For more information about the proposed AML requirements, see Seward & Kissel LLP Client Alert: FinCEN Proposes AML Requirements for Registered Investment Advisers at http://xlo3.wpengine.com/pubs/xprPubDetail.aspx?xpST=PubDetail&pub=710.


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Investment Advisers, Investment Companies