If terrorists and drug runners need to launder illicit gains, are hedge funds the perfect vehicle?  Since 2001, regulators and legislators have debated subjecting hedge funds to anti-money laundering rules like those in place for banks, broker-dealers and other financial institutions.  Despite the promulgation of specific rules and significant legislative pressure, hedge funds remain largely outside the purview of anti-money laundering regulations.  Now, new moves from U.S. financial regulators suggest that, after a decade of false starts, hedge funds may be brought into the fold.  The history of these proposed regulations sheds light on the question of whether hedge funds even pose the kind of threat the rules were designed to ameliorate.  In a guest article, Michael B. Himmel and Matthew M. Oliver, both Members of Lowenstein Sandler PC, provide a comprehensive overview of U.S. anti-money laundering legislation and regulation over the past decade, and conclude with a discussion of recent anti-money laundering developments that have direct bearing on hedge funds, hedge fund managers and investors.