Investment Adviser AML Rule Postponed!

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to postpone the effective date of the final rule establishing 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) and to revisit the scope of the IA AML Rule. FinCEN anticipates delaying the effective date of the IA AML Rule from January 1, 2026, until January 1, 2028.

FinCEN will provide the IA sector with regulatory certainty by issuing appropriate exemptive relief delaying the effective date. FinCEN will revisit the substance of the IA AML Rule and, together with the Securities and Exchange Commission, also intends to revisit the joint proposed rule establishing customer identification program rule requirements for investment advisers. The full text of FinCEN’s announcement is available here.

This latest postponement follows a series of similar delays and repeals of rules applicable to investment advisers, reflecting shifting priorities in the oversight of the sector. If you would like to discuss the state of regulations currently applicable to your investment adviser firm, contact a member of the Orical team.