February 13, 2024
Contact: IAA VP of Communications & Marketing Janay Rickwalder.
The Investment Adviser Association fully supports efforts to combat money laundering and terrorist financing, but these efforts must be risk-based and designed to fill identified gaps in the existing AML regulatory landscape rather than duplicate the protections that already exist.
Based on our initial review, the IAA is concerned that the sweeping proposal, which will capture virtually all investment advisers regardless of risk or gaps in the current framework, will not accomplish this because it lacks sufficient tailoring to the unique business models and risk profiles of investment advisers. Adding these sweeping and duplicative requirements could unnecessarily burden advisers without providing significant additional benefit.
We are also concerned that the Treasury Department’s Risk Assessment is pulling into the AML bucket risks that are distinct from AML and illicit financing. For example, it reflects that fraud is a main driver for the proposal. Investment advisers already comply with broad anti-fraud regulations and are required to implement programs designed to detect and prevent fraudulent activity, and the SEC has and exercises broad enforcement authority.
The IAA urges the Treasury Department to develop a tailored approach that effectively addresses specific risks while avoiding unnecessary regulatory burdens, especially burdens on smaller investment advisers.
The IAA provides links to web sites of other organizations in order to provide visitors with certain information. A link does not constitute an endorsement of content, viewpoint, policies, products or services of that web site. Once you link to another web site not maintained by the IAA, you are subject to the terms and conditions of that web site, including but not limited to its privacy policy.
Click the link above to continue or CANCEL
