Client Alert
The Securities and Exchange Commission recently issued a no-action letter which grants relief to broker-dealers, allowing them to rely on investment advisers to perform some or all of their Customer Identification Program obligations under federal anti-money laundering legislation. The letter extends existing relief granted in 2013 that was set to expire in January of 2015. The 2015 no-action letter, which is the latest in a line of letters dating back to 2004, will expire in January of 2017 or the date upon which an anti-money laundering program rule for investment advisers becomes effective.
