Clifford Chance
Implications of FinCEN’s proposed rule implementing AML program and suspicious activity reporting requirements for Non-US investment advisers
4 December 2015
On August 25, 2015, the Financial Crimes Enforcement Network issued a notice of proposed rulemaking (the Proposed Rule) which would require investment advisers that are registered (or required to be registered) with the US Securities and Exchange Commission to establish an anti-money laundering program and file suspicious activity reports in response to certain indications of illegal activity observed by the adviser.
