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Overview of CIP Regulations for Mutual Funds and Broker-Dealers by Diane E. Ambler Andras P. Teleki Kirkpatrick & Lockhart Preston Gates Ellis LLP Washington Office
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June 5, 2004
Previously published on May 2003
On April 30, 2003, the Department of Treasury, jointly with the relevant federal functional regulators, adopted final rules requiring mutual funds and broker-dealers, as well as banks and trust companies, savings associations, credit unions, futures commission merchants and futures introducing brokers, to implement a customer identification program ("CIP") by October 1, 2003, as part of their anti-money laundering programs ("AML Programs"). This eBulletin covers the CIP rules for mutual funds and broker-dealers, issued in two separate joint Securities and Exchange Commission and Treasury Releases, which are virtually identical.
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The views expressed in this article are solely the views of the author and not Martindale-Hubbell. This article is intended for informational purposes only and is not legal advice or a substitute for consultation with a licensed legal professional in a particular case or circumstance. |
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