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ARTICLE · 27 FEBRUARY 2024

FinCEN Proposes AML Program Rule For Investment Advisers

Goodwin Procter LLP
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The Financial Crimes Enforcement Network ("FinCEN"), a bureau within the U.S. Treasury Department, has issued a proposed rule (the "Proposal") that would subject certain investment advisers to anti-money...

United StatesGovernment, Public Sector
Gregory Larkin
Gregory Larkin
Brynn Peltz
Brynn Peltz
William Stern
William Stern
Alexander J. Callen
Alexander J. Callen

The Financial Crimes Enforcement Network ("FinCEN"), a bureau within the U.S. Treasury Department, has issued a proposed rule (the "Proposal") that would subject certain investment advisers to anti-money laundering ("AML") and countering terrorist financing ("CTF") compliance requirements under the Bank Secrecy Act (the "BSA"). In proposing the rule, FinCEN cited concerns that investment advisers could be exploited by illicit actors to gain access to the U.S. financial system or by foreign governments to obtain access to or information about certain technologies and services with national security implications.

This client alert provides an overview of (i) which investment advisers would be subject to the Proposal, (ii) the AML program requirements investment advisers would become subject to under the Proposal, (iii) the reporting and recordkeeping requirements, including the suspicious activity report ("SAR") requirements, investment advisers would need to comply

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