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On 13 February 2024, the Financial Crimes Enforcement Network (FinCEN) issued a groundbreaking Notice of Proposed Rulemaking (NPRM) to combat illicit finance and national security threats in the investment adviser sector. The proposed rule would subject certain investment advisers to anti-money laundering and countering the financing of terrorism (AML/CFT) requirements pursuant to the Bank Secrecy Act (BSA), including requirements to maintain AML/CFT programs, report suspicious activity to FinCEN, and fulfill BSA recordkeeping requirements.
Given both the breadth of the anticipated obligations and the challenges of securing compliance resources at impacted firms outside of standard budgetary cycles, it is important for investment advisers to begin planning immediately to ensure that effective systems and processes are in place to meet new AML/CFT requirements when the final rule goes live.
In this one-hour session our panel of experts discuss the new regulatory obligations anticipated under the proposed rule, timelines for finalization and compliance, and how investment advisers should prepare in the months ahead. You’ll hear from Alex Levitov, managing director at K2 Integrity; Melissa Goldstein, partner at Schulte Roth & Zabel; and moderator Sarah Runge, executive managing director at K2 Integrity.
By the end of this session, you will be able to:
- Explain the history and context of the proposed investment adviser rule
- Summarize the regulatory requirements of the proposed rule
- Discuss how to prepare for key rulemaking and compliance milestones in the months ahead
- Describe near- and medium-term priorities for ensuring full compliance when the rule goes live
