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FinCEN Proposes Anti-Money Laundering Regulation Applicable to Unregistered Investment Companies

September 01, 2002

By Securities Practice Group

Pursuant to the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001, on September 18, 2002, the Financial Crimes Enforcement Network of the Department of the Treasury proposed new anti-money laundering Rule 132 under the Bank Secrecy Act that would require “unregistered investment companies” to establish anti-money laundering programs. The proposed definition of unregistered investment companies is very broad, and includes certain commodity pools, companies that invest in real estate, and investment companies exempt from registration under the Investment Company Act of 1940. The proposed requirements are substantially the same as those FinCEN has established for mutual funds.

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