FinCen IA AML Rule Postponed
News and Alerts
On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to postpone the effective date of the Anti-Money Laundering/Countering the Financing of Terrorism Program and Suspicious Activity Report Filing Requirements for Registered Investment Advisers and Exempt Reporting Advisers (IA AML Rule) from January 1, 2026 until January 1, 2028.
FinCEN has recognized that the rule must be effectively tailored to the diverse business models and risk profiles of the Investment Adviser sector, and that extending the effective date may help ease potential compliance costs for the industry and reduce regulatory uncertainly while FinCEN undertakes a broader review of the IA AML Rule.
There were some highlighted areas FinCEN covers that they will work through the rulemaking process to extend the effective date below:
- Provide the IA sector with regulatory certainty by issuing appropriate exemptive relief delaying the effective date.
- FinCEN intends to revisit the substance of the IA AML Rule through a future rulemaking process.
- FinCEN, together with the SEC, intends to revisit the joint proposed rule establishing Customer Identification Program Rule requirements for Investment Advisers, Customer Identification Programs for Registered Investment Advisers and Exempt Reporting Advisers.