Please refer to the published rule for further details, including definitions. Ia aml rule on september 4, 2024, fincen published the ia aml rule, which defined certain investment advisers as ``financial institutions'' under the bank secrecy act (bsa).\2\ the ia aml rule requires covered ias to establish aml/cft programs, report suspicious activity, and keep relevant records, among other requirements.\3\ in the 2024. Further, covered advisers must conduct a risk assessment and independent testing of their aml program and will be required to share certain additional information with fincen, law enforcement, and other financial institutions as required by section 314 of the patriot act.
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According to the final rule release, investment advisers should review customer agreements for existing clients to understand the nature and the purpose of the customer relationship in order to develop a customer risk profile and to identify and report suspicious activity on a risk basis.
Examiners, now required to assess ias’ compliance with the final rule starting in 2026, will be looking for documentation supporting all aspects of the new requirements.
For compliance officers and executive leadership at investment advisers, fincen’s aml rule and its recent updates represent a paradigm shift in how the advisory industry approaches financial crime risk. Rule mandates aml/cft programs and sar reporting for most investment advisers, expanding the regulatory perimeter to “close the gap” in regulatory coverage and enhance efforts to thwart illicit finance
