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[…]

Anti-Money Laundering Compliance: The Basics

About a month ago, FINRA announced that it would be fining Raymond James & Associates and Raymond James Financial Services for $17 million for widespread failures in Anti-Money Laundering (AML) compliance. The former AML Compliance Officer at Raymond James & Associates, Linda Busby, was suspended three months and fined for $25,000 herself. No one at Raymond James, Ms. Busby or otherwise, was participating in the intense, dramatic money-laundering schemes seen in fiction; instead, the firms simply grew much more quickly than their compliance systems did, resulting in many possible incidents of suspicious activity going undetected or uninvestigated. As Raymond James’ recent fine shows, it is very important to keep up-to-date with AML Compliance. Read More…