The Financial Crimes Enforcement Network proposed rules requiring Securities and Exchange Commission-registered investment advisers to establish anti-money laundering procedures, report suspicious activities to FinCEN, file reports of certain transactions involving US $10,000 in currency (so-called “Currency Transaction Reports”) and maintain records related to the transmittal of funds in excess of US $3,000. The obligations would also extend to persons required to be registered with the SEC as investment advisers, but who are not. Typically, only investment advisers with US $100 million or more in regulatory assets under management are required to register with the SEC. FinCEN previously had proposed rules to mandate AML programs for registered and unregistered investment advisers in 2002 and 2003, but withdrew them in 2008. Comments to the proposal are due by end of day on October 26, 2015. (Click here for additional information on the proposed rules in an August 31, 2015 Advisory by by Katten Muchin Rosenman LLP.)