ANALYSIS: Zombie Hedge Fund AML Rules Threaten to Reanimate

Regulatory proposals for imposing anti-money laundering requirements on hedge funds and other unregistered investment companies have staggered around the legal landscape for two decades.

Such proposals to apply AML requirements to these entities and their human hosts (that is, their investment advisers) have lingered for years in a suspended state, neither fully alive as adopted rules nor fully dead.

Recent reports warn that a 2015 proposal to establish AML requirements for investment advisers may reanimate under the Biden administration. But a look back at 20 years of experience should temper any expectations that a viable rule survives after six years ...