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Is the AML Rule for Investment Advisors Coming?

As we approach the 20th anniversary of the first proposed anti-money laundering (AML) rule for investment advisors (IAs) next year, we reflect on whether an IA rule may finally be passed, and what firms can do to prepare.

Notably, in June 2022, the ENABLERS Act was added to the 2023 National Defense Authorization Act. If passed in its current form, investment advisors would be required to establish AML programs, report suspicous activity, implement due dilgience controls, and identify and verify account holders.

Potentially impacted firms should consider:

  1. Socializing the possibility with the board of directors, senior management, and key stakeholders.
  2. Mapping operational processes, particularly with third party service providers such as administrators and custodians.
  3. Assessing existing risk management processes.

Guidehouse’s financial crime consultants work with financial institutions of all types and sizes, to build effective and efficient risk management and compliance programs. In response to heightened regulatory scrutiny of anti-money laundering (AML), sanctions, anti-bribery and corruption (ABC), and anti-fraud policies, companies turn to Guidehouse to defend their enterprises and protect against financial crime, legal, regulatory, shareholder, and reputational risk. Most importantly, we can help investment advisers develop an efficient and proactive compliance program, enabling the identification and mitigation of issues before they become a regulatory and business risk. We view sound risk management as a competitive advantage that can preserve capital and provide the flexibility to withstand regulatory change.



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