Currently, there is no AML Program Rule in the US for SEC Registered Investment Advisors (RIAs) or their administrators. The Bank Secrecy Act (“BSA”) and implementing regulations establish the basic framework for AML obligations imposed on financial institutions. The Financial Crimes Enforcement Network (“FinCEN”) adopted the “AML Program Rule” and the “SAR Rule” to implement AML programs and suspicious activity monitoring and reporting requirements for broker-dealers¹.