ICI Supports Anti-Money Laundering Programs for Unregistered Funds

Washington, DC, November 22, 2002 - The Institute strongly supports Treasury's efforts to combat money laundering in the financial services industry, including a proposed rule that would require all investment companies that are not registered under U.S. law to adopt and implement anti-money laundering programs.

In a recent comment letter, the Institute recommends two changes to the proposed rule in order to more appropriately tailor its application. First, the Institute recommends that offshore publicly sold funds, which are already subject to strong anti-money laundering regimes outside the United States, be exempted from the final rule. Second, the Institute recommends changes to the definition of "unregistered investment company" that would limit the scope of the rule to funds with U.S. investors. The Institute noted that this change would limit the scope of the proposed rule to those funds that rely on the 1940 Act to avoid registration as an investment company in the United States.