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 finalized a rule adding certain SEC-registered and exempt reporting investment advisers to the BSA's "financial institution" definition, requiring them to maintain AML/CFT programs and file suspicious activity reports.

Minimal direct impact. The rule covers investment advisers, not money-services businesses; BlockQuake is already a BSA-defined financial institution through its state money-transmitter licenses, so its existing AML/BSA and SAR obligations are unchanged by this rulemaking.

No compliance action required—monitor only if BlockQuake stands up or acquires an RIA/advisory affiliate that would fall in scope.