FinCEN acknowledges that its definition of investment advisers includes different investment advisers that may have varying degrees of AML/CFT risks. As is more broadly the case under the BSA, the AML/CFT compliance program requirement is risk based, meaning that an AML/CFT compliance progr...
Christian Goecking, graduate of the HEC, University of Lausanne, has spent 35 years in banking, finance, and particularly in financial brokerage. He has worked in senior management and as deputy director at major Swiss banks and English brokerage houses. He was Manager of private asset ...