Alert November 22, 2011

FinCEN To Develop Rules Requiring Investment Advisers To Establish Anti-Money Laundering Programs

In a speech given at the American Bankers Association/American Bar Association AML Enforcement Conference, FinCEN Director James H. Freis, Jr. stated that “FinCEN is currently revisiting the topic of investment advisers, building on the changes to that industry pursuant to the Dodd-Frank Act, the SEC rules implementing Dodd-Frank and other changes, and is working on a regulatory proposal that would require investment advisers to establish AML programs and report suspicious activity. We look forward to working with the SEC as well as the States as we move forward.”  The Alert will follow this initiative as it develops.