Financial Crimes Enforcement Network: Anti-Money Laundering/Countering the Financing of Terrorism Program and Suspicious Activity Report Filing Requirements for Registered Investment Advisers and Exempt Reporting Advisers

FinCEN proposes adding certain investment advisers (RIAs and ERAs) to the BSA's "financial institution" definition, requiring them to maintain AML/CFT programs and file suspicious activity reports.

Minimal direct impact. BlockQuake is a money-services business already subject to BSA AML and SAR obligations as a state-licensed money transmitter, while this rule covers investment advisers — a category its exchange, custody, and staking lines do not occupy. It was flagged on AML/BSA/FinCEN keywords, not because it creates new duties.

Monitor only; act sooner only if BlockQuake operates or acquires a registered or exempt investment-adviser entity.