The Future of AML for Investment Advisers

The Fourth EU Anti-Money Laundering Directive and FinCEN’s Proposed Rules


On August 25, 2015, the Financial Crimes Enforcement Network (FinCEN) proposed a rule requiring investment advisers registered with the U.S. Securities and Exchange Commission (SEC) to establish anti-money laundering (AML) programs and file suspicious activity reports (SARs);[1] however, European Union (EU) Member States are already expected to require investment firms to comply with the AML regulations applicable to all financial institutions through the EU’s Fourth Directive on the Prevention of the Use of the Financial System for the Purpose of Money Laundering and Terrorist Financing (Fourth Directive). This regulation went into force on June 26, 2015 and adds customer due diligence, suspicious transactions reporting and other requirements which have significant implications for investment advisers.

In Guidehouse’s new article, our experts discuss the future of AML for investment advisers with a comparison of FinCEN’s proposed rule to the present EU regime’s approach and a discussion of the changes both will bring for investment advisers.

[1] 31 CFR Chapter X. RIN: 1506-AB10. See:

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