Today, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule to extend the effective date of the 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 (IA AML Rule) from January 1, 2026, until January 1, 2028.
This final rule follows the notice of proposed rulemaking that FinCEN issued on September 22, 2025, and the exemptive relief order issued on August 5, 2025. For more information, see the final rule as well as Treasury’s past announcement of FinCEN’s intention to postpone and review the IA AML Rule.
Update 12/31/2025: Final rule: Delaying the Effective Date of the Anti-Money Laundering/Countering the Financing of Terrorism Program and Suspicious Activity Report Filing Requirements for Registered Investment Advisers and Exempt Reporting Advisers