On February 13, 2024, the US Department
of the Treasury, acting through the Financial
Crimes Enforcement Network (FinCEN),
issued proposed rules that would require
certain investment advisers to comply with
the Anti-Money Laundering and Countering
the Financing of Terrorism (AML/CFT)
requirements of the Bank Secrecy Act (BSA),
to file suspicious activity reports (SARs) and to
comply with certain other recordkeeping and
notification requirements of the BSA. FinCEN
has requested public comments on these
proposed rules by April 14, 2024.