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Interim Final Rules on Anti-Money Laundering Programs Issued for Investment Companies, Broker-Dealers and Other Financial Institutions

May 01, 2002

By Paul Hastings Professional

Funds and Exempted Investment Companies will soon be required to establish and maintain Programs in compliance with Treasury’s interim final rules under the Act and other BSA requirements – and broker-dealers must have Programs in place that comply with their SRO’s anti-money laundering rules as of April 24, 2002. Additionally, Programs will need to be updated as Treasury issues new rules and regulations through FinCEN in the coming months, including updating Programs to include procedures to verify the identification of customers consistent with regulations to be issued by Treasury by October 26, 2002. It also is likely that Funds, and possibly Exempt Investment Companies, will be required to submit Suspicious Activity Reports and may also be required to provide law enforcement agencies with information about certain accounts.