HOUSEKEEPING, REMINDERS AND UPDATES: AUGUST 2015
FINANCIAL CRIMES ENFORCEMENT NETWORK In an August 25, 2015, press release, the Financial Crimes Enforcement Network (“FinCEN”) announced proposed anti-money laundering (“AML”) regulations for investment advisers. FinCEN has published a Notice of Proposed Rulemaking regarding AML programs and suspicious activity report (“SAR”) requirements that would apply to certain investment advisers. The purpose of FinCEN’s proposed rule is to prescribe minimal standards for AML programs to be established by certain investment advisers and to require such investment advisers to report suspicious activity to FinCEN pursuant to the Bank Secrecy Act (“BSA”). The proposed rules would apply to Securities and Exchange Commission (“SEC”) registered investment advisers and investment advisers required to be registered with the SEC, which includes advisers to certain hedge funds, private equity funds and other private funds. The action to be taken by FinCEN in the proposed rulemaking is to address the issue of money laundering and terrorist financing...