New FinCEN Anti-Money Laundering Requirements for Investment Advisers (September 2024) I. Overview On August 28, 2024, the Financial Crimes Enforcement Network (“FinCEN”) issued a new Final Rule (the “AML Rule”) imposing anti-money laundering (“AML”) obligations on certain investment advisers who are either registered with the Securities and Exchange Commission (“SEC”, and such advisers, “SEC RIAs”) or are considered “exempt reporting advisers” with the SEC (“SEC …
New FinCEN Beneficial Ownership Reporting Requirements for Private Fund Managers and Other Companies (January 2024)
The United States Corporate Transparency Act (the “CTA”) was passed by the United States Congress in early 2023 to improve financial transparency and increase the effectiveness of anti-money laundering efforts. However, the CTA will also impose several obligations on millions of entities (each, a “Reporting Company”), including private fund advisers and the private funds they advise (subject to certain exceptions as outlined below) to continuously …