The Financial Crimes Enforcement Network (FinCEN) is proposing a rule that would require investment advisors to comply with Bank Secrecy Act requirements, including implementing anti-money laundering controls and filing suspicious activity reports. Unlike previous attempts, this proposal does not hold investment advisors accountable for identifying their clients, but FinCEN is considering a separate proposal with the SEC for future customer ID requirements. With an increased push from regulators and illicit actors’ growing utilization of RIA intermediaries for AML purposes, the investment advisory sector may soon face stricter regulations, particularly regarding customer identification.