Best Practices for Hedge Fund Managers to Adopt in Anticipation of Enactment of FinCEN AML Rule Proposal

After more than a decade in the works, the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of Treasury, released proposed rules in August 2015 that will subject registered investment advisers to anti-money laundering (AML) regulation once adopted. See our two-part series on how hedge fund managers can respond to the AML rules proposed by FinCEN: “Establish an AML Program” (Nov. 5, 2015); and “Operate an AML Program” (Nov. 12, 2015). Cadwalader, Wickersham & Taft recently presented a program examining the current AML regime, the requirements of the proposed rules and how those changes will affect hedge fund managers. The program featured Maureen Dollinger, a vice president of financial crime legal at Barclays; Adam Gehrie, general counsel and chief compliance officer (CCO) of Gresham Investment Management; and Cadwalader partners Dorothy Mehta and Joseph Moreno. This article highlights the portions of the panel’s discussion most relevant to hedge fund managers and other investment advisers. For further insight from Mehta, see our two-part series on SEC remote examinations: “What to Expect” (May 12, 2016); and “How to Prepare” (May 19, 2016); as well as “Practical Guidance for Hedge Fund Managers on Preparing For and Handling NFA Audits” (Oct. 17, 2014).

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