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

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. 

Chapters

• 0:47 A recap of what FinCEN is proposing
• 2:50 How real is the risk of bad actors exploiting RIAs or ERAs
• 5:37 A hypothetical scenario
• 8:22 The momentum behind FinCEN's push and the potential burden for investors
• 9:43 FinCEN's expectations for customer due diligence
• 13:32 Advice on screening high risk investors