Cyber-SARs

Anti-money laundering and cybersecurity rules

MICHAEL L. YAEGER, MELISSA G. R. GOLDSTEIN, JENNIFER M. OPHEIM AND NICHOLAS DINGELDEIN, SCHULTE ROTH & ZABEL LLP

Investment advisers may soon have a new cybersecurity reporting requirement from a federal regulator. Anti-money laundering (“AML”) requirements have recently been interpreted to include cybersecurity suspicious activity reporting (“SAR”) requirements, so if AML obligations are extended to investment advisers, then these newly articulated cybersecurity reporting obligations will follow.

And AML obligations are on the horizon: On August 25, 2015, the US Department...

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