The FACT Coalition along with 10 other organizations filed a comment on April 4, 2016 with the Department of the Treasury to finalize the proposed rule issued by the Financial Crimes Enforcement Network (FinCEN) to impose anti-money laundering and suspicious activity reporting requirements on registered investment advisers. The full letter can be read below or downloaded here.
April 4, 2016
The Honorable Jack Lew
Secretary, U.S. Department of the Treasury
1500 Pennsylvania Avenue, NW
Washington, DC 20220
The Honorable Shaun Donovan
Director, U.S. Office of Management and Budget
725 17th Street, NW
Washington, DC 20503
The Honorable Jennifer Shasky Calvery
Director, U.S. Department of the Treasury
Financial Crimes Enforcement Network (FinCEN)
P.O Box 39
Vienna, VA 22183
Re: Anti-Money Laundering Requirements for Registered Investment Advisers RIN 1506-AB10; Docket Number FINCEN-2014-0003
Dear Secretary Lew, Director Donovan, and Director Shasky Calvery:
We are writing to urge prompt action to finalize the proposed rule issued by the Financial Crimes Enforcement Network (FinCEN) to impose anti-money laundering and suspicious activity reporting requirements on registered investment advisers. Finalizing this rule would ensure that these advisers, each of which manages $100 million or more in assets, know their customers, report suspect transactions to law enforcement, and contribute to the work of the U.S. financial community to protect the United States from money launderers, terrorists, and other wrongdoers.
U.S. law already imposes anti-money laundering (AML) obligations on banks, securities firms, money service businesses, insurance firms, commodity brokers, and other members of the U.S. financial industry. Registered investment advisers that collectively bring billions of dollars into the U.S. financial system should be subject to the same obligations. Many already have voluntary programs; all have the means and sophistication to implement an AML program in compliance with the rule. Virtually all of the comment letters express support for the rule’s objectives. Adopting the rule would also bring U.S. AML requirements in closer alignment with global practice and international AML standards.
In this last year of the Obama Administration, this proposed rule deserves priority attention for strengthening a key U.S. defense against money laundering that furthers terrorism, drug trafficking, organized crime, and tax evasion. It would close a major, decade-old gap that has allowed hedge funds, private equity funds, and other big investment firms to accept substantial funds with no questions asked, to facilitate the transfer of offshore funds into the United States without determining their source, and to witness troubling transactions with no legal obligation to report them.
Thank you for your time and attention.
American Federation of Teachers (AFT)
Americans for Financial Reform
Financial Accountability and Corporate Transparency (FACT) Coalition
Global Financial Integrity
Main Street Alliance
New Rules for Global Finance
About the FACT Coalition
The Financial Accountability and Corporate Transparency (FACT) Coalition is a non-partisan alliance of more than 100 state, national, and international organizations working toward a fair tax system that addresses the challenges of a global economy and promoting policies to combat the harmful impacts of corrupt financial practices.
1225 Eye St. NW, Suite 600 | Washington, DC | 20005 | USA
+1 (202) 827-6401 | @FACTCoalition | www.thefactcoalition.org