Anti-Money Laundering Program and Suspicious Activity Report Filing Requirements for Registered Investment Advisers

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Financial Crimes Enforcement Network ("FinCEN"), a bureau of the Department of the Treasury ("Treasury"), is issuing this notice of proposed rulemaking to prescribe minimum standards for anti-money laundering programs ("AML") to be established by certain investment advisers and to require such investment advisers to report suspicious activity to FinCEN pursuant to the Bank Secrecy Act ("BSA"). FinCEN is taking this action to regulate investment advisers that may be at risk for attempts by money launderers or terrorist financers seeking access to the U.S. financial system through a financial institution type not required to maintain AML programs or file suspicious activity reports ("SARs"). The investment advisers FinCEN proposes to cover by these rules are those registered or required to be registered with the U.S. Securities and Exchange Commission ("SEC"). FinCEN is also proposing to include investment advisers in the general definition of "financial institution" in rules implementing the BSA. Doing so would subject investment advisers to the BSA requirements generally applicable to financial institutions, including, for example, the requirements to file Currency Transaction Repo