“A square peg in a round hole” is the application of FinCEN’s proposed anti-money laundering rules to the traditional investment advisory model, according to investment management counsel David Tittsworth (Washington, D.C.). Mr. Tittsworth’s remarks were featured in ACA Compliance Group’s Nov. 9 newsletter, ACA Insight, in a piece outlining how comment letters sent by the Investment Adviser Association, the Managed Funds Association and the Private Equity Growth Capital Council—three organizations representing key segments of the asset management industry—all support anti-money laundering, but through differing approaches. Mr. Tittsworth also outlined that while some of the proposed measures are duplicative, the differing viewpoints should be carefully considered by FinCEN, even though “it may determine that simply covering virtually all SEC-registered advisers is the best way to proceed.”
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