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ARTICLE · 19 SEPTEMBER 2024

FinCEN Extends AML Obligations To Investment Advisers

Ropes & Gray LLP
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On 28 August, the U.S. took a small step towards closer alignment with the anti-money laundering (AML) regimes of the UK and the EU when the Financial Crimes Enforcement Network (FinCEN)...

GlobalGovernment, Public Sector
Sarah Lambert-Porter
Sarah Lambert-Porter
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On 28 August, the U.S. took a small step towards closer alignment with the anti-money laundering (AML) regimes of the UK and the EU when the Financial Crimes Enforcement Network (FinCEN) issued a new rule (Final Rule), which effectively extends certain AML compliance obligations to:

  • Registered investment advisers (RIAs) (including 'foreign-located investment advisers') registered with the Securities and Exchange Commission (SEC); and
  • Investment advisers that report to the SEC as exempt reporting advisers (ERAs).

We have covered the details of the Final Rule in an earlier Alert, but, in a nutshell:

  • The U.S. Bank Secrecy Act (BSA), the principal federal statute governing AML requirements for financial institutions in the U.S., requires firms falling within the definition of "financial institution" to establish and maintain AML compliance programs with several minimum/mandatory features (the 'BSA AML Obligations'). The Final Rule amended the BSA by

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