The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced today 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 (the IA AML Rule) from January 1, 2026, until January 1, 2028. 

In addition to the announcement of the delayed effective date, FinCEN noted its intention to:

• Issue appropriate exemptive relief delaying the effective date;
• Revisit the substance and scope of the IA AML Rule through a future rulemaking process; and
• Together with the Securities and Exchange Commission (SEC), 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.