In an article for Family Wealth Report, White & Case partner Joel Cohen discussed the impact that new requirements imposed by the final Anti-Money Laundering Rule from the US Treasury Department's Financial Crimes Enforcement Network will have on RIAs with over US$110 million in assets.
The article explains that the rule will impose several new compliance responsibilities on wealth managers, and Joel noted that the requirement to file suspicious activity reports (SARs) "may be the biggest initial difficulty for RIAs."
Joel emphasized that "RIAs need to understand the significant limitations on sharing the contents of SAR reports with external sources or even within their organizations," and he warned against RIAs importing "the full range of anti-money laundering controls and processes that non-RIA institutions are obliged to follow."
To comply with the new requirements, Joel said, "RIAs will need to designate a person responsible for implementing the program, and providing supplemental training for the appropriate personnel, which means identifying which personnel that includes, and implementing risk-based customer due diligence."
Read the full article here.
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