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ARTICLE · 09 SEPTEMBER 2024

FinCEN Adopts Final Rule: AML Programs For Investment Advisers

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On August 28, the US Department of the Treasury's Financial Crimes Enforcement Network issued a final rule that expands anti-money laundering and countering the financing of terrorism program requirements to cover Securities and Exchange Commission registered investment advisers and SEC exempt reporting advisers.

United StatesGovernment, Public Sector
Adam Bolter
Adam Bolter
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On August 28, the US Department of the Treasury's (Treasury Department) Financial Crimes Enforcement Network (FinCEN) issued a final rule that expands anti-money laundering (AML) and countering the financing of terrorism (CFT) program requirements to cover Securities and Exchange Commission (SEC) registered investment advisers (RIAs) and SEC exempt reporting advisers (ERAs) (collectively, Investment Advisers).

Background

The road to finalizing AML requirements applicable to Investment Advisers has been decades long. The rationale for the rulemaking is based, in part, on a risk assessment conducted by the Treasury Department, which noted that The People's Republic of China and the Russian Federation have sought to leverage investment advisers and their advised funds through investment in early stage companies to access certain technologies and services with national security implications.

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