The SEC together with FinCEN issued a joint notice of proposed rulemaking to apply customer identification program obligations to certain investment advisers. This rulemaking is intended to complement the separate February 2024 FinCEN proposal to designate RIAs and ERAs as “financial institutions” under the Bank Secrecy Act and subject them to AML/CFT program requirements, as well as obligations to file suspicious activity reports. The comment period for the proposed rulemaking ends on July 22, 2024.