Editor’s Note: For more information about AML regulations, see Unwarranted Deputization: Increased Delegation of Law Enforcement Duties to Financial Institutions Undermines American Competitiveness.
From: Lexology
Michael J. Gilbert and Ethan Solove – Dechert LLP
It has been more than a decade since the Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) first proposed imposing anti-money laundering (“AML”) requirements on investment advisers. While FinCEN has yet to enact such a rule, the possibility of investment adviser AML regulations continues to lurk over the industry and a new proposed regulation may be in the works.
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