AML Compliance Ahead: Navigating the Upcoming FinCEN Requirements
STP’s Cynthia Kelly, Senior Compliance Consultant was a key contributor to the IAA’s IAA Today Smart Brief on the upcoming FinCEN Requirements.
On August 28, 2024, the Financial Crimes Enforcement Network (FinCEN), part of the U.S. Department of the Treasury, issued its final rule titled Anti-Money Laundering/Countering the Financing of Terrorism Program and Suspicious Activity Report Filing Requirements for Registered Investment Advisers and Exempt Reporting Advisers (Final Rule). This rule significantly expands the scope of anti-money laundering (AML) requirements by including most SEC-registered investment advisers (RIAs) and all Exempt Reporting Advisers (ERAs) (jointly referred to as “advisers”) in the broader regulatory framework that was previously limited to more traditional financial institutions like banks, mutual funds, and broker-dealers.
The Final Rule will come into effect on January 1, 2026, and mandates that advisers subject to the rule (“covered advisers”) establish a risk-based comprehensive AML compliance program, conduct customer due diligence, and adhere to independent testing and reporting requirements, such as filing Suspicious Activity Reports (SARs) with FinCEN. These are just some of the adopted changes that are part of an ongoing effort to strengthen the financial system against money laundering, terrorist financing, and other illicit financial activities.
If you are a member or associate member of IAA, you can access the article here.
*as previously published in the Investment Adviser Association’s IAA Today
