February 27, 2013

SEC No-Action Relief for Broker-Dealers Relying on Registered Investment Advisers for Anti-Money Laundering Obligations

The SEC has extended a former no-action letter position that permitted broker-dealers to rely on SEC registered investment advisers to perform its customer identification obligations for shared customers.  The former position allows broker-dealers to rely on certain financial institutions to meet customer identification obligations under Rule 17a-8 of the Securities Exchange Act of 1934 as long as the institution is subject to an anti-money laundering program regulated by a federal regulator.

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