On May 13th, the SEC, in conjunction with the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN), proposed new rulemaking under which SEC-registered investment advisers (RIAs) and exempt reporting advisers (ERAs) would be required to establish, document, and maintain written customer identification programs (CIPs) appropriate for their respective sizes and businesses. The new rule is intended to prevent illicit finance activity concerning the customers of investment advisers by enhancing the anti-money laundering and countering the financing of terrorism (AML/CFT) framework for the investment adviser sector.
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