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Toomey Talks SEC and FinCEN’s Recent Customer-Identification Proposal

May 17, 2024

Kevin Toomey, head of the firm’s Financial Services practice, was quoted in the ACAMS: Money article, “SEC Proposes Beneficial Ownership Requirement for US Investment Advisers.” The article discusses the recent proposal from the U.S. Securities and Exchange Commission’s (SEC) and U.S. Department of the Treasury’s Financial Crimes Enforcement Network’s (FinCEN) which outlines customer-identification requirements for SEC-registered investment advisers (RIAs) and exempt reporting advisers (ERAs). The proposal aims to fill a gap in U.S. anti-financial crime defenses and requires investment advisors to no longer work with clients whose identities they fail to obtain.

Toomey told ACAMS: Money that “there will certainly be entities newly covered by these written rules that will have to get up to speed and establish [customer-identification] programs,” but “from a practical perspective, many investment advisers are already doing this,” such as RIAs and ERAs run by banks.

Read the full article (subscription required).