On May 13, 2024, the Securities and Exchange Commission (SEC) and the Financial Crimes Enforcement Network (FinCEN) issued a joint notice to apply customer identification program (CIP) obligations to certain investment advisers.
Under the Proposed Rule, RIAs and ERAs will be required to:
- • Identify and verify the identity of anyone seeking to open an account or invest in a fund managed by the RIA or ERA.
- • Maintain verification information, including name, address, date of birth (or date of entity formation), and identification number (e.g., social security number or employer identification number).
- • Check whether the person appears on any government-issued lists of known or suspected terrorists or terrorist organizations.