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ARTICLE · 21 MAY 2024

FinCEN (And SEC) Propose New Customer Identification Program Rule With Minimal Expected Impact On Private Fund Sponsors

Goodwin Procter LLP
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On May 13, 2024, the Financial Crimes Enforcement Network (FinCEN), a bureau within the U.S. Treasury Department, and the Securities and Exchange Commission (SEC) proposed a joint rule (the Proposed Rule) with respect to a customer identification program.

United StatesGovernment, Public Sector
Gregory Larkin
Gregory Larkin
William Stern
William Stern
Cynthia Wells
Cynthia Wells

On May 13, 2024, the Financial Crimes Enforcement Network (FinCEN), a bureau within the U.S. Treasury Department, and the Securities and Exchange Commission (SEC) proposed a joint rule (the Proposed Rule) with respect to a customer identification program (CIP) for investment advisers that is a companion to the anti-money-laundering/countering the financing of terrorism (AML/CFT) program rule proposed by FinCEN on February 15, 2024.1

Key Highlights

  • Similar to the AML/CFT program rule, the Proposed Rule would cover both SEC-registered investment advisers and exempt reporting advisers and apply equally to both U.S. and non-U.S. advisers with respect to both U.S. and non-U.S. clients.

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