AIMA has written to support the FinCEN proposal to delay the application of the Bank Secrecy Act anti-money laundering program requirements to investment advisers for two years until 1 January 2028.

FinCEN has also published new FAQs setting out its expectations of when suspicious activity reporting should be done, with an emphasis on greater proportionality focussing more on higher risk activity. The four new FAQs relate to:

• SAR Filings for Potential Structuring-related Activity
• Continuing Activity Reviews
• Continuing Activity Reviews – Timeline
• SAR Documentation