- Compliance Services
- Cybersecurity & Risk
- Performance Services
- Technology Solutions
- Events & Education
It has been over 10 years in the making, but FinCEN has re-proposed an AML rule for SEC-registered advisers. As proposed, advisers would be required to:
The proposed rule does not require advisers to establish a customer identification program (CIP), which is typically required for banks, broker-dealers, and other financial institutions. FinCEN indicated that CIP requirements, as well as the applicability of other sections of the Patriot Act, would be addressed via additional rulemaking.
If you have questions about the proposed rule, please contact Nick Prokos or your ACA consultant.