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Understanding the Implications for Hedge Fund Managers of FinCEN’s Final AML Rules, Hedge Fund Law Report

21. November 2024

Partner Christine Lombardo was quoted in a Hedge Fund Law Report article discussing the US Department of the Treasury’s Financial Crimes Enforcement Network’s final anti-money laundering (AML) rules.

In addressing some of the key challenges, HFLR reports that “the AML policies and programs that private fund advisers currently have in place are unlikely to satisfy all of the Rules’ requirements – and some elements of the Rules may pose a challenge for advisers.” Christine commented that “[e]ven a manager that has an AML policy in place will need to reassess its existing procedures and practices in light of the Rules.”

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