Simpson Thacher Attorneys Author LexisNexis Article on Takeaways from FinCEN AML Final Rule
02.14.25
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Partners Abram Ellis and David Blass, and Associate Christine Tillema, authored an article titled, “Investment Adviser Anti-Money Laundering (AML) Checklist,” which was published by LexisNexis. The article explored key takeaways from 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. It further discussed the considerations for registered investment advisers and exempt reporting advisers as they develop and adopt written policies and procedures to ensure compliance prior to the January 1, 2026 effective date.
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