Financial Regulation International
US
Treasury Proposes to Extend Anti-Money Laundering Program Requirements to Investment Advisers
Robert Bagnall, Satish Kini and Jonathan Hecht. Wilmer Cutler & Pickering, Washington DC
On April 29, 2003, the Treasury Department proposed a rule (the “Proposed Rule”) that would require certain investment advisers
to establish anti-money laundering programs
1
. Treasury issued the proposal under the
USA PATRIOT Act
(the “Patriot Act”), a law enacted in the wake of the September 11, 2001 terrorist attacks to combat the financial aspects
of terrorism and international money laundering. Investment advisers covered under the Proposed Rule would need to develop
written anti-money laundering policies and procedures, designate a person or persons to be responsible for anti-money laundering
compliance, train appropriate employees with regard to money laundering, and periodically audit or test the functioning of
their anti-money laundering compliance efforts. The Proposed Rule is open for public comment until July 7, 2003.