FinCEN intends to reissue a joint NPRM with the Securities and Exchange Commission, implementing Section 326 of the Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001 (USA PATRIOT Act) with regard to customer identification program (CIP) requirements for certain investment advisers. This proposal would replace the previous IA CIP NPRM that FinCEN published on May 21, 2024. Specifically, as in the originally proposed rule, FinCEN would require a registered investment adviser (RIA) and an exempt reporting adviser (ERA) to establish a CIP as part of an AML/CFT program. RIAs and ERAs would be required to implement reasonable procedures to identify and verify the identity of their customers, among other requirements, in order to form a reasonable belief that RIAs and ERAs know the true identity of their customers. FinCEN anticipates, however, that in the reissued proposed rule these requirements would be more effectively tailored to the diverse business models and risk profiles of types of firms within the investment adviser sector than in the originally proposed rule.