Simpson Thacher Attorneys Author Law360 Article on FinCEN AML Rule Delay
08.15.25
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Partner Abram Ellis, Counsel Jim Perry and Associate Christine Tillema authored an article, “What FinCEN's AML Rule Delay Means For Advisers,” which was published by Law360. The article discusses the U.S. Department of the Treasury's recent announcement of its intention to delay the implementation of its final rule related to anti-money laundering programs, countering the financing of terrorism programs and suspicious activity reports. It further explores the background and required compliance of the investment adviser AML rule as currently written, which is now slated to go into effect by January 1, 2028, and what the delay means for covered advisers that had already started the necessary work to ensure compliance with the IA AML rule in advance of the initial January 1, 2026, compliance date.
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