AML Update: SEC and FinCEN Propose Anti-Money Laundering and Customer Identification Programs For Investment
K&L Gates – The SEC and the US Department of Treasury’s (DoT) Financial Crimes Enforcement Network (FinCEN) jointly proposed rulemaking to implement Section 326 of the USA Patriot Act1 (Proposed CIP Rule), which would require SEC-registered investment advisers (RIAs) and exempt reporting advisers (ERAs) to establish written customer identification programs (CIP).
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