FinCEN issued a final rule to include both RIAs and ERAs in the definition of “financial institution” under the Bank Secrecy Act. The rule aims to help address the illicit finance risks in the investment adviser sector in the United States and to help level the regulatory playing field through a consistent application of risk-based AML/CFT requirements. The compliance date for this rule is January 1, 2026. In the coming months, we will work with all clients to ensure that policies and procedures are properly updated, training of relevant employees has been conducted, and that firms are prepared to comply with the new rulemaking prior to the compliance date.