FinCEN Postpones the Implementation of the Investment Adviser Rule

On July 21, 2025, FinCEN announced it 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 (IA AML Rule). The action, according to FinCEN, is to ensure efficient regulation that appropriately balances costs and benefits.

The IA AML Rule seeks to address ongoing illicit finance risks, threats, and vulnerabilities posed by criminals and foreign adversaries that exploit the U.S. financial system and assets through investment advisers.  However, FinCEN said that it recognizes that the rule must be effectively tailored to the diverse business models and risk profiles of the investment adviser sector. FinCEN anticipates delaying the effective date of the IA AML Rule from January 1, 2026, until January 1, 2028. FinCEN will also revisit the scope of the IA AML Rule at a future date. 

Read the Treasury’s press release here.

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