Anne C. Choe

Anne C. Choe is a Partner in the Firm’s Registered Funds and Funds Regulatory and Investigations Practices. She represents investment managers, registered funds and private funds on a broad range of regulatory and transactional matters. Her experience covers a variety of fund structures, including exchange-traded funds, mutual funds and private funds and she also regularly counsels family offices and independent boards. She has in-depth knowledge of the various securities and other laws applicable to investment managers and funds, including the Investment Company Act of 1940 and the Investment Advisers Act of 1940. She also has deep experience representing investment advisers and funds in SEC examination and enforcement matters.

Anne additionally has significant experience advising investment management firms in registering with the SEC as investment advisers, as well as advising on exemptions from registration for U.S. and non-U.S. firms. She assists clients in connection with internal compliance reviews and investigations, as well as on the development and testing of compliance programs.

She routinely counsels clients on compliance with adviser fiduciary duties, the marketing rule, the custody rule, the “pay-to-play” rule and e-communications, as well as the implementation of compliance programs as required by Rule 206(4)-7 under the Advisers Act. Her diverse practice also includes advising on the creation and operation of registered open-end investment companies and ETFs. She is also regularly involved in advising on investment management M&A transactions. Anne serves as lead independent board counsel to several mutual fund, ETF and interval fund boards.

Chambers Global (2021-2025) and Chambers USA (2020-2024) recognize Anne in the category of Investment Funds: Regulatory & Compliance, where she is commended by clients who note that she is “professional and practical, with a keen ability to explain complex regulatory framework applications.” The Legal 500 US (2023-2024) recognizes Anne as a next Generation Partner in the category of Investment Fund Formation and Management: Mutual/Registered/Exchange-Traded Funds.

In addition, Anne was featured by Lawyers of Color in its inaugural “Wonderful Women” list in 2023, which recognizes “dynamic women attorneys working in law firms, companies, and government agencies across the U.S. who show promise in their careers and demonstrate a strong commitment to advancing diversity in the legal profession.”

Notable experience prior to joining Simpson Thacher includes representing:

• A private equity firm in an SEC investigation relating to compliance with the SEC’s “pay-to-play” rule
• A private equity firm in an SEC enforcement matter relating to fees and expenses
• A private credit manager in an SEC investigation relating to valuation
• An investment adviser and a registered fund complex in obtaining a novel exemptive order from the SEC.
• An investment manager in an internal investigation related to private fund fiduciary matters

Anne received her J.D. in 2009 from the University of North Carolina School of Law and her B.S. in 2002 from the University of Maryland. She is admitted to practice in the District of Columbia and Maryland.