On July 21, 2025, FinCEN announced its intention to postpone the effective date of the final rule requiring Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) programs and Suspicious Activity Report (SAR) filing for registered investment advisers and exempt reporting advisers (the “IA AML Rule”).
FinCEN intends to delay the rule’s effective date from January 1, 2026, to January 1, 2028, to allow time for a broader review of the rule’s scope and to ensure it is appropriately tailored to the investment adviser industry’s varied business models and risk profiles. While this delay is not yet official, FinCEN has stated they will be working through the rulemaking process to formalize the extension.
In addition, FinCEN and the SEC plan to revisit the previously proposed joint rule related to customer identification program (CIP) requirements for investment advisers during this extended timeframe.
While the IA AML Rule remains a priority, this delay provides additional time for firms to prepare for future compliance requirements.
We will continue to monitor developments and keep you informed as FinCEN releases further guidance. Please don’t hesitate to reach out with any questions or to discuss what this means for your firm.