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Proposed AML/CFT Program Rule for Covered Investment Advisers: 6 Things To Know

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  • Proposed AML/CFT Program Rule for Covered Investment Advisers: 6 Things To Know

On February 13, 2024, the Department of the Treasury’s (“Treasury”) Financial Crimes Enforcement Network (“FinCEN”) released a notice of proposed rulemaking (the “Proposal”) to make certain investment advisers, including advisers of many venture capital and private equity funds, subject to anti-money laundering regulation under the Bank Secrecy Act (“BSA”). The Proposal would, among other things, require such investment advisers to establish anti-money laundering/countering the financing of terrorism (“AML/CFT”) programs and report suspicious activity to FinCEN. FinCEN also released a fact sheet on the Proposal.

Below are six key takeaways from the Proposal. Comments on the Proposal are due by April 15, 2024.

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