FinCEN delays its Investment Adviser AML Rule’s effective date from 2026 to 2028, aiming to refine anti-illicit finance measures while easing compliance for firms with diverse risk profiles

On July 21, 2025, the U.S. Department of the Treasury’s FinCEN announced a delay in the effective date of the Investment Adviser AML Rule—from January 1, 2026 to January 1, 2028—while committing to review the rule’s scope to ensure it accounts for the varied business models and risk profiles in the IA sector. During the postponement, FinCEN, together with the SEC, plans to issue exemptive relief and revisit related proposed customer identification requirements, aiming to provide clarity and reduce regulatory uncertainty…