As we approach the mid-point of 2025, two compliance deadlines stand out for compliance professionals, amended Regulation S-P and FinCEN’s Anti-money laundering/countering the financing of terrorism Rule (the “AML/CFT” Rule).
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On February 13, 2024, the Financial Crimes Enforcement Network (FinCEN) proposed a new rule to combat the investment of illicit funds in the U.S. financial system. The proposed rule would require certain investment advisers to apply Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) requirements pursuant to the Bank Secrecy Act (BSA).
The reasons OCIE may select an adviser for examination are various and shifting, depending on commonly identified risk factors and changes in regulation. The SEC takes steps to be transparent about which conditions may cause an adviser to be selected for examination.