New Anti-Money Laundering Program Requirements

Recently, the Financial Crimes Enforcement Network (“FinCEN”) adopted a final rule on Customer Due Diligence (“CDD”) Requirements for Financial Institutions.   As a result, firms will be required to address the new requirements within their Anti-Money Laundering (AML) programs.  Firms must be in compliance with its provisions by May 11, 2018. Read More…

AML-CIP Requirements for Private Placement Transactions

The world of private placement transactions is one that is highly scrutinized by both FINRA and the SEC. It seems that with all of the Ponzi schemes and actions for misappropriation of investor monies, private placement transactions are always on the regulators’ exam priorities lists. With that in mind, it is imperative that firms participating in such offerings ensure that their compliance programs are kept current and up-to-date. However, an area that is often overlooked in such compliance preparation is the Anti-Money Laundering (“AML”) / Customer Identification Program (“CIP”) process. Read More…

AML Requirements for Investment Advisers

The U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) has proposed rulemaking that would require registered investment advisers to establish anti-money laundering (“AML”) programs and to file suspicious activity reports (“SARs”). The new requirements, as proposed, may impose significant regulatory burden on certain investment advisers. In this blog post, we provide a summary of the proposal to help your firm assess the potential impact, if any, the new requirements would have on your firm’s business. We conclude by providing, as a reminder, a list of the limited AML requirements that currently apply to investment advisers. Read More…

Anti-Money Laundering Compliance: The Basics

We have updated this post! We are leaving this post up as to not disturb any saved links; however, please visit our more recent post, FINRA Rule 3310: Anti-Money Laundering Compliance Program, for current information on the topic.

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