Regulatory Notice: SEC AML No-Action Relief Letter Extended – “CIP Reliance Letter”

The Securities and Exchange Commission (“SEC”) extended its long standing No-Action Relief Letter that allows broker-dealers to rely on SEC registered investment advisers to perform some or all of their customer identification program (“CIP”) rule, 31 C.F.R. § 1023.220 (“CIP Rule”), and/or the portion of the customer due diligence rule regarding beneficial ownership requirements for legal entity customers, 31 C.F.R. § 1010.230.

This December 12, 2018 CIP No-Action Relief Letter will expire in December of 2020 or earlier if the AML program rule for investment advisers becomes effective.

You may view the No-Action Relief Letter here: https://www.sec.gov/divisions/marketreg/mr-noaction/2018/sifma-120718-17a8.pdf