Anti-Money Laundering and Suspicious Activity Reporting Requirements Proposed Rulemaking (02/13/24)

The U.S. Department of Treasury’s Financial Crimes Enforcement Network proposed rulemaking that would require both RIAs and ERAs to apply AML/CFT requirements pursuant to the Bank Secrecy Act, including implementing risk-based AML/CFT programs, reporting suspicious activity to FinCEN, and fulfilling recordkeeping requirements. The comment period for the proposed rulemaking ends on April 15, 2024.