April 15, 2024
Contact: IAA VP of Communications & Marketing Janay Rickwalder.
Statement from Gail Bernstein, IAA General Counsel
The Investment Adviser Association fully supports efforts to combat money laundering and terrorist financing, but additions to the robust AML regulatory regime we already have in the United States must be risk-based and designed to fill identified gaps in the existing landscape rather than duplicate the protections that already exist.
The IAA is concerned that the sweeping proposal, which will capture virtually all investment advisers regardless of risk or gaps in the current framework, will not achieve this balance because it lacks sufficient tailoring to the unique business models and risk profiles of investment advisers. Adding these sweeping and duplicative requirements could unnecessarily burden advisers without providing significant additional AML benefit.
The IAA has urged the Treasury Department to develop a tailored approach that effectively addresses specific risks while avoiding unnecessary practical and operational burdens, especially burdens on smaller advisers. Specifically, the IAA’s recommendations include:
The IAA believes that by implementing these recommendations, the Treasury Department can create a comprehensive, protective AML framework without imposing unnecessary burdens on advisers.
The full comment letter is available on the IAA website.
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