The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN“) has announced its intent to delay the effective date of the Anti-Money Laundering/Countering the Financing of Terrorism (“AML/CFT“) rule for Registered Investment Advisers and Exempt Reporting Advisers (“IA AML Rule“) from January 1, 2026, to January 1, 2028.
Key Highlights:
- Effective Date Postponed: The IA AML Rule’s implementation date is now expected to shift from January 1, 2026 to January 1, 2028.
- Broader Review Underway: FinCEN will reassess the scope of the rule to ensure it is appropriately tailored to varying business models and risk profiles within the investment adviser sector.
- Exemptive Relief Anticipated: Regulatory certainty will be maintained during this period through exemptive relief measures.
- Additional Rule Reassessment: FinCEN, in collaboration with the SEC, also plans to revisit the proposed Customer Identification Program rule requirements for investment advisers.
What This Means for You: This postponement offers breathing room for firms to prepare, plan, and assess AML/CFT obligations with greater clarity. While formal requirements are delayed, the risk landscape continues to evolve, and we encourage a proactive approach to safeguarding compliance operations.
Click here for the full press release.
If you have any questions or would like to discuss how this update may affect your firm, please don’t hesitate to get in touch.
