On May 13, 2024, the US Securities and Exchange Commission (“SEC”) and the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a joint notice of proposed rulemaking (the “CIP Proposal”) that would apply customer identification program obligations to SEC registered investment advisers and exempt reporting advisers. In this Legal Update, we provide background on recent efforts by the US government to expand the scope of AML compliance obligations to new markets and market participants, a summary of the CIP Proposal, and a discussion of key takeaways from the CIP Proposal and FinCEN and the SEC’s invitation for public comment on its contents. 

Continue reading this Legal Update.