
James C. Munsell
Articles
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May 17, 2024 |
jdsupra.com | Brian Daly |Nnedinma Ifudu Nweke |James C. Munsell
Key Points On May 13, 2024, the U.S. Securities and Exchange Commission (“SEC”) and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a joint notice of proposed rulemaking, Customer Identification Programs for Registered Investment Advisers and Exempt Reporting Advisers (“Joint NPRM”), that would require SEC-registered investment advisers (“RIAs”) and exempt reporting advisers (“ERAs”) to establish, document and maintain written customer...
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Feb 14, 2024 |
lexology.com | Peter Altman |Michael Asaro |Brian Daly |Jason Daniel |Katherine Goldstein |Alexis Guinan | +11 more
Key PointsOn February 13, 2024, FinCEN issued an NPRM that seeks to include certain investment advisers in the definition of “financial institution” under the BSA. As described in the NPRM as well as in FinCEN’s fact sheet, RIAs and ERAs would be required to implement risk-based AML/CFT programs, file SARs with FinCEN, fulfill certain recordkeeping requirements and fulfill other obligations currently applicable to financial institutions subject to the BSA and FinCEN’s implementing regulations.
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