FinCEN proposed to include "investment adviser" in the definition of "financial institution" under the Bank Secrecy Act. The proposed rule would require advisers to implement AML/CFT programs and maintain recordkeeping requirements.
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The SEC set an effective date of November 13, 2023 and outlined compliance dates for significant new regulation of private fund advisers under the Advisers Act.
Several industry trade associations filed a Petition for Review in the U.S. Court of Appeals for the Fifth Circuit seeking to "hold unlawful, vacate, and set aside" the SEC's final rules on private funds advisers. The associations argued that the SEC has "not shown any need for the intrusive rules it has adopted."
The SEC reopened and extended the comment deadline until October 30, 2023 on a proposal to significantly amend and redesignate the Advisers Act "Custody Rule," expanding its requirements.
The SEC adopted significant new regulation of private fund advisers under the Advisers Act, as well as other requirements that apply to all SEC-registered investment advisers.