Our Investment Services team just published its March 2024 Regulatory Update, analyzing a wide selection of federal agency enforcement actions and initiatives in Q1. You can access the articles below.
March 2024 Investment Services Regulatory Update
FinCEN Proposes Rule to Address Anti-Money Laundering Risks to Registered Investment Advisers and Exempt Reporting Advisers
On February 13, 2024, the Financial Crimes Enforcement Network (FinCEN) issued a proposed rule1 that would extend certain anti-money laundering/countering the financing of terrorism (AML/CFT) program requirements to investment advisers registered with the Securities and Exchange Commission (SEC) and exempt reporting advisers (ERAs) with the SEC.
The proposed rule would require certain covered advisers