The Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking that would require registered investment advisers to establish anti-money laundering programs and file suspicious activity reports with FinCEN in certain circumstances. FinCEN also is proposing to include investment advisers in the general definition of “financial institution” under the Bank Secrecy Act of 1970 (BSA). This change would subject investment advisers to multiple BSA requirements, including the obligation to file Currency Transaction Reports and to keep records relating to the transmittal of funds.

Comments are due on or before October 26.

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