Anti-Money Laundering Content

The Financial Crimes Enforcement Network (FinCEN) has proposed new rules requiring SEC-registered investment advisers and exempt reporting advisers to establish anti-money laundering/countering the financing of terrorism (AML/CFT) programs and report suspicious activity to FinCEN...

For the twelfth year in a row, the SEC office responsible for conducting inspections of registrants, the Division of Examinations, has published its examination priorities for the coming year. While the Division has commonly published its examination priorities near the beginning of...

On September 25, 2023, the SEC's Division of Enforcement announced charges against a registered investment adviser ("Adviser") for causing mutual funds it advises ("Mutual Funds") to fail to develop and implement a reasonably designed anti-money laundering ("AML") program. The Adviser...

On July 31, the SEC Division of Examinations ("Division") published a risk alert ("Risk Alert") regarding anti-money laundering ("AML") compliance examinations of broker-dealers. The Risk Alert highlights the Division's observations that: some broker-dealers "did not appear to devote...

For the eleventh year in a row, the SEC's Division of Examinations (EXAMS) has published its priorities for the coming year. Highlights of the Priorities are briefly described below.

On December 15, 2022, the Financial Crimes Enforcement Network ("FinCEN") issued a proposed rule ("Proposed Rule") regarding access to beneficial ownership information ("BOI"). The Proposed Rule follows a recently adopted BOI reporting rule ("BOI Reporting Rule") and is the second of...