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ARTICLE · 18 OCTOBER 2024

Private Funds Radar - October 2024

Macfarlanes LLP
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Macfarlanes LLP

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A new rule issued by the Financial Crimes Enforcement Network (FinCEN) will bring investment advisers – including private fund sponsors – within the scope of the US anti-money...

GlobalFinance and Banking

The private funds radar is our regular roundup of developments from around the world for private fund stakeholders.

US

New anti-money laundering obligations for private fund sponsors

A new rule issued by the Financial Crimes Enforcement Network (FinCEN) will bring investment advisers – including private fund sponsors – within the scope of the US anti-money laundering and counter-terrorist financing (AML/CFT) regime.

The new rule, which applies from 1 January 2026, has an extra-territorial element: it will apply to the activities of non-US sponsors (including those who file with the SEC as exempt reporting advisers) if:

  • those activities take place within the US; or

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