SEC Extends AML Relief: Broker-Dealers May Rely on Investment Advisers to Perform CIP Obligations; FinCEN Indicates Potential Investment Adviser AML Program Rule

January 22, 2015

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.

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