On February 13, 2024, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a Notice of Proposed Rulemaking (NPRM). This would, for the first time, require SEC-Registered Investment Advisers (RIAs) and Exempt Reporting Advisers (ERAs) to create and implement risk-based anti-money laundering and countering the financing of terrorism (AML/CFT) programs, file suspicious activity reports (SARs) with FinCEN, and comply with certain other recordkeeping and notification rules.

The Proposed Rule is scheduled to be published February 15, 2024, in the Federal Register, with public comments due by April 14, 2024. The draft NPRM is available here.

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