Simpson Thacher Attorneys Author Law360 Article on Takeaways from the FinCEN AML Final Rule
09.20.24
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Partners Abram Ellis and David Blass, and Associate Christine Tillema, authored an article titled, “7 Takeaways For Investment Advisers From FinCEN AML Rule,” which was published by Law360. The article explored FinCEN’s long-awaited final rule that will define most SEC-registered investment advisers and exempt reporting advisers as “financial institutions” for purposes of certain anti-money laundering laws and regulations under the Bank Secrecy Act. The piece further detailed key takeaways from the final rule, in addition to discussing the considerations for registered investment advisers and exempt reporting advisers as they examine their written policies and procedures in the lead up to the effective date.
To read the full article, click here (subscription required).