Shareholder Thomas D. Giachetti, Chair of the Securities Practice Group, authored the article Treasury Considers Anti-Money Laundering Regs, which was published in the October 2015 issue of Investment Advisor Magazine.
The article details the potential anti-money laundering (ALM) program requirements that the Financial Crimes Enforcement Network (FinCEN) is planning to implement. These regulations would be targeting SEC-registered investment advisors, and would require advisors to “adopt and maintain an anti-money laundering program, file suspicious activity reports and comply with additional reporting requirements.”
FinCEN, which is a bureau of the U.S. Department of the Treasury, previously recognized in 2007 that SEC advisors were not required adopt an AML program, because independent custodians must undertake the AML exercise before an advisory account can be opened. These additional regulations will only serve to bog down small- and medium-sized advisory firms which are already subject to a number of other regulations.
According to Mr. Giachetti, “The result of these additional regulations is less profits (this administration doesn’t care about advisory firm “fat cats” — how little it really knows), and more importantly, less resources to spend with clients.”
You can read the full article by clicking here.
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