ARTICLE · 26 JUNE 2024

SEC & FinCEN Propose Customer ID Program Rule For RIAs & ERAs

Michael Best

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Earlier this year, the Financial Crimes Enforcement Network ("FinCEN") issued a proposed rule that would bring SEC-registered investment advisers and Exempt Reporting Advisers...

United StatesGovernment, Public Sector

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

Earlier this year, the Financial Crimes Enforcement Network ("FinCEN") issued a proposed rule that would bring SEC-registered investment advisers and Exempt Reporting Advisers ("Covered Advisers") within the scope of key U.S. anti-money laundering ("AML") rules (see our prior alert for more information). However, that proposal did not require Covered Advisers to adopt and maintain a Customer Identification Program ("CIP"), since any such rule must be adopted alongside the SEC.

On May 13, 2024, the SEC and FinCEN issued a joint proposed rule (the "Proposed Rule") to require covered investment advisers to implement CIPs. The SEC/FinCEN have issued the Proposed Rule to prevent customers from using false identities to establish advisory relationships with Covered Advisers in order to launder money through the

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