HOUSEKEEPING, REMINDERS AND UPDATES: AUGUST 2015

FINANCIAL CRIMES ENFORCEMENT NETWORK In an August 25, 2015, press release, the Financial Crimes Enforcement Network (“FinCEN”) announced proposed anti-money laundering (“AML”) regulations for investment advisers. FinCEN has published a Notice of Proposed Rulemaking regarding AML programs and suspicious activity report (“SAR”) requirements that would apply to certain investment advisers. The purpose of FinCEN’s proposed rule is to prescribe minimal standards for AML programs to be established by certain investment advisers and to require such investment advisers to report suspicious activity to FinCEN pursuant to the Bank Secrecy Act (“BSA”). The proposed rules would apply to Securities and Exchange Commission…

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