教授，博士生導師。復旦大學中國反洗錢研究中心首任主任，復旦大學俄...
復旦大學國際金融學院教授，中國反洗錢研究中心執行主任，陸家嘴金...
復旦大學法學院教授、博士生導師；復旦大學國際刑法研究中心主任。...
華東政法大學刑法學教授，復旦大學中國反洗錢研究中心特聘研究員，荷...
安永金融服務風險管理、咨詢總監，曾任螞蟻金服反洗錢總監，復旦大學...
周錦賢先生，香港人，廣州暨南大學法律學士，復旦大學中國反洗錢研究中...
高級經濟師，復旦大學金融學博士，復旦大學經濟學博士后。現供職于中...
武漢中南財經政法大學信息安全學院教授。長期專注于反洗錢/反恐...
生辰：1977.7.26 籍貫：遼寧撫順 民族：漢 黨派：九三學社 職稱：教授 研究...
祝亞雄，1974年生，浙江衢州人。浙江師范大學經濟與管理學院副教授，博...
復旦大學中國反洗錢研究中心特聘研究員；現任安永管理咨詢服務合伙...
工作履歷：曾在國家審計署從事審計工作，是國家第一批政府審計師；曾在...
https://bettermarkets.org/newsroom/secs-customer-identification-programs-rule-is-essential-to-prevent-money-laundering-terrorist-financing-and-sanctions-evasion/
WASHINGTON, D.C.— Director of Securities Policy Benjamin Schiffrin issued the following statement on the filing of Better Markets’ Comment Letter to the Securities and Exchange Commission (SEC) regarding its proposed rule to require that investment advisers implement reasonable procedures to verify the identity of their customers.
“Investment advisers play a crucial role in our financial system. And money laundering, terrorist financing, and sanctions evasion pose a grave threat to that financial system and our national security. But unlike banks and broker-dealers, many investment advisers are not subject to any obligations to have a program dedicated to anti-money laundering or countering the financing of terrorism (AML/CFT). This creates a huge gap in the regulations that are designed to prevent criminals and terrorists from accessing the U.S. financial system. The SEC’s rule fills that loophole in the AML/CFT regulatory framework by subjecting investment advisers to similar regulatory obligations as other market participants.
“The SEC’s rule requires that investment advisers establish, document, and maintain a written customer identification program (CIP) as part of an AML/CFT program. The CIP must include procedures for verifying the identity of customers that allow the investment adviser to form a reasonable belief that it knows the customer’s true identity. This is essential to prevent criminal enterprises and sanctions evaders from using investment advisers as a gateway to the U.S. financial system and as a means of circumventing the safeguards in place at banks and broker-dealers and avoiding detection of illicit activities.
“AML/CFT programs and CIPs are essential to protect the U.S. economy and security and the global financial system. But those policies and procedures will only be effective if they are comprehensive. The failure to require that investment advisers have AML/CFT programs that include CIPs is a fundamental weakness in those policies and procedures. Criminal enterprises and sanctions evaders have taken, and will continue to take, advantage of that vulnerability. As a result, the SEC’s proposed rule is an essential measure to ensure that our AML/CFT policies are able to prevent money laundering and other illicit financial activity.”