ARTICLE · 13 JUNE 2024

FinCEN Issues Proposed Rule Requiring Customer Identification Programs For Investment Advisers

McDermott Will & Schulte

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

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Melissa G.R. Goldstein

Betty Santangelo

Kyle B. Hendrix

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On May 13, 2024, the US Department of the Treasury's Financial Crimes Enforcement Network ("FinCEN") and the Securities and Exchange Commission ("SEC") jointly issued a notice of proposed rulemaking ("CIP Proposed Rule") that would apply customer identification program ("CIP") obligations to investment advisers registered with the SEC ("RIAs") and exempt reporting advisers ("ERAs") (collectively, "Covered Advisers").¹ The CIP Proposed Rule would require Covered Advisers, among other things, to implement a risk-based CIP that includes procedures for verifying the identity of each customer to the extent reasonable and practicable, and maintaining records of the information used to verify a customer's identity, including name, address and other identifying information. The CIP Proposed Rule would require Covered Advisers to establish CIPs comparable to those required for other financial institutions, such as banks and broker-dealers.

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