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 …