UPDATE: On July 21, 2025, U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a press release announcing its intention to postpone the effective date of the final rule requiring registered investments advisers and exempt reporting advisers to implement anti-money laundering (AML) programs (IA AML Rule).  FinCEN recognized that an extension of the effective date of the IA AML Rule may help ease potential compliance costs for industry and reduce regulatory uncertainty. FinCEN plans to undertake a broader review and to revisit the substance and scope of the IA AML Rule through a future rulemaking process in order to tailor it to the diverse business models and risk profiles of the investment adviser sector. FinCEN also intends to work with the Securities and Exchange Commission to revisit the joint proposed rule establishing customer identification program rule requirements for investment advisers.

FinCEN anticipates delaying the effective date of the IA AML Rules from January 1, 2026, until January 1, 2028.

What is required under the IA AML Rule? 

As we previously reported in Investment Advisers to Launch AML Programs January 1, 2026, the IA AML Rule requires certain investment advisers (including both registered investment advisers (RIAs) and exempt reporting advisers (ERAs)) to implement AML programs to help law enforcement prevent money laundering, terrorist financing and other illicit finance activity. The IA AML Rule aims to bring investment advisers within the federal AML framework that already exists for banks, broker-dealers, insurance companies and certain other financial institutions under the Bank Secrecy Act (BSA).

Under the IA AML Rule, investment adviser AML programs must consist of (i) internal policies, procedures and controls reasonably designed to mitigate AML risk, (ii) independent testing of the investment adviser’s AML program, (iii) an AML compliance officer, (iv) ongoing AML training, and (v) appropriate risk-based procedures for conducting ongoing “customer” due diligence.

What should investment advisers be doing now? 

During this extension, investment advisers should continue working with their internal and external compliance and legal functions to design and implement an AML program that complies with these new requirements. RIAs should, if they have not already, implement and maintain systems to monitor for Specially Designated Nationals and Blocked Persons List of the Office of Foreign Assets Control of the U.S. Department of the Treasury as part of their compliance and investor due diligence programs. Furthermore, RIAs should track and file Currency Transaction Reports as required and monitor criminal money laundering statutes outside the BSA. Certain bank-affiliated RIAs may still be subject to the BSA AML requirements based on their affiliation with a bank, and notwithstanding the delay in the IA AML rules.