SEC No-Action Relief Under Broker-Dealer CIP Rule and Beneficial Ownership Requirements for Legal Entity Customers
On December 5, 2025, the SEC renewed its No-Action Relief Under Broker-Dealer Customer Identification Program Rule (31 C.F.R. § 1023.220) and Beneficial Ownership Requirements for Legal Entity Customers (31 C.F.R. § 1010.230). Please view this “No-Action Letter” here: https://www.sec.gov/files/tm/no-action/nal-sifma-120524.pdf
Additionally, on August 28, 2024, FinCEN issued a new rule to include certain investment advisers in the definition of “financial institutions” under the Bank Secrecy Act, prescribe minimum standards for anti-money laundering/countering the financing of terrorism (“AML/CFT”) programs to be established by certain investment advisers, require certain investment advisers to report suspicious activity to FinCEN pursuant to the Bank Secrecy Act, and make several other related changes to FinCEN regulations (the “IA AML Program Rule”). 3 The IA AML Program Rule is effective January 1, 2026.
On September 19, 2025, FinCEN issued a notice of proposed rulemaking to extend the effective date of the final rule establishing Anti-Money Laundering/Countering the Financing of Terrorism Program and Suspicious Activity Report Filing Requirements for Registered Investment Advisers and Exempt Reporting Advisers (IA AML Rule) from January 1, 2026, until January 1, 2028.
Ref: https://www.sec.gov/files/tm/no-action/nal-sifma-120524.pdf
Ref: https://www.federalregister.gov/documents/2024/09/04/2024-19260/financial-crimes-enforcement-network-anti-money-launderingcountering-the-financing-of-terrorism
Ref: https://www.fincen.gov/news/news-releases/fincen-issues-proposed-rule-postpone-effective-date-investment-adviser-rule
