On July 21, 2025, the Financial Crimes Enforcement Network (FinCEN) announced that it is delaying the effective date of the investment adviser anti-money laundering rule (IA AML Rule) for two years from 1 January 2026 to 1 January 2028.
During the delay in the effective date FinCEN plans to reopen the IA AML Rule and revisit the scope and substance of that rule through future rulemaking. At the same time, FinCEN will work with the SEC to revisit the joint proposed rule establishing customer identification program requirements for investment advisers (IA CIP Rule).
This announcement addresses two key industry concerns. First, FinCEN acknowledges that the scope of the IA AML Rule, which covers SEC registered investment advisers and exempt reporting advisers, should be more narrowly tailored in recognition of the "diverse business models and risk profiles of the investment adviser sector"; and second, it addresses widespread criticism that investment advisers did not have the opportunity to consider the IA AML Rule and the IA CIP Rule at the same time because the comment period for the IA AML Rule closed before the IA CIP Rule was proposed. This announcement presumably will give investment advisers the opportunity to review and comment on both proposals simultaneously—thus providing visibility into the full scope and substance of potential AML regulation for investment advisers.
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