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ARTICLE · 01 JUNE 2024

SEC And FinCEN Propose Customer Identification Program Requirements For Certain Investment Advisers

Mayer Brown
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On May 13, 2024, the US Securities and Exchange Commission ("SEC") and the US Department of the Treasury's Financial Crimes Enforcement Network...

United StatesFinance and Banking
Matthew Bisanz
Matthew Bisanz
Adam Kanter
Adam Kanter
Brad Resnikoff
Brad Resnikoff
Dylan C. Platt
Dylan C. Platt
Kelly F. Truesdale
Kelly F. Truesdale
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I. INTRODUCTION

On May 13, 2024, the US Securities and Exchange Commission ("SEC") and the US Department of the Treasury's Financial Crimes Enforcement Network ("FinCEN") issued a joint notice of proposed rulemaking (the "CIP Proposal") that would apply customer identification program ("CIP") obligations to SEC registered investment advisers ("RIAs") and exempt reporting advisers ("ERAs," and collectively with RIAs, "SEC Advisers").1

The CIP Proposal complements—and was foreshadowed by—FinCEN's February 2024 proposal to impose anti-money laundering ("AML") compliance program obligations on SEC Advisers (the "AML Proposal"). As we discussed in a prior Legal Update, the AML Proposal would expand the definition of "financial institution" under the Bank Secrecy Act ("BSA") and its implementing regulations to include SEC Advisers and would impose, among other things, AML compliance obligations requiring SEC Advisers to (1) adopt a risk-based AML compliance program;

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This Mayer Brown article provides information and comments on legal issues and developments of interest. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide legal advice. Readers should seek specific legal advice before taking any action with respect to the matters discussed herein.

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