The CIP Proposal complements—and was foreshadowed by—FinCEN’s February 2024 proposal to impose anti-money laundering (“AML”) compliance program obligations on SEC Advisers (the “AML Proposal”). As we ...

The SEC and FinCEN Request Comments on their Proposed Rule on Customer Identification Programs for Registered Investment Advisers and Exempt Reporting Advisers The Securities and Exchange Commission ( ...

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Financial institutions operate in an environment where trust, compliance, and fraud prevention are inseparable. To protect the financial system from money laundering, terrorist financing, and identity ...