RiskWatch

FinCEN Proposes Significant Expansion of AML/CFT Obligations to RIAs and ERAs

March 26, 2024 Vcheck / Amy Caizza / Wilson Sonsini Episode 38
FinCEN Proposes Significant Expansion of AML/CFT Obligations to RIAs and ERAs
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RiskWatch
FinCEN Proposes Significant Expansion of AML/CFT Obligations to RIAs and ERAs
Mar 26, 2024 Episode 38
Vcheck / Amy Caizza / Wilson Sonsini

Amy Caizza, a Partner at Wilson Sonsini, discusses new proposed rules by FinCEN that would see a significant expansion of AML / CFT obligations for Registered Investment Advisers, Venture Capital Advisers, and Private Fund Advisers. This could mean a significant addition to advisers’ obligations when screening potential investors. Here is a link to the recent alert that the firm published on the proposed rule as well as a link to Amy’s bio and contact information.

Amy is leader of the firm’s fintech and financial services group, which is recognized as a leading U.S. fintech practice by Chambers FinTech. 

Show Notes Chapter Markers

Amy Caizza, a Partner at Wilson Sonsini, discusses new proposed rules by FinCEN that would see a significant expansion of AML / CFT obligations for Registered Investment Advisers, Venture Capital Advisers, and Private Fund Advisers. This could mean a significant addition to advisers’ obligations when screening potential investors. Here is a link to the recent alert that the firm published on the proposed rule as well as a link to Amy’s bio and contact information.

Amy is leader of the firm’s fintech and financial services group, which is recognized as a leading U.S. fintech practice by Chambers FinTech. 

A recap of what FinCEN is proposing
How real is the risk of bad actors exploiting RIAs or ERAs
A hypothetical scenario
The momentum behind FinCEN's push and the potential burden for investors
FinCEN's expectations for customer due diligence
Advice on screening high risk investors