FinCEN Delays AML Rule for Investment Advisers Until 2028, With Revisions Likely
By Janaya Moscony
SEC3 President
August 19, 2025 | SEC3 Compliance
On July 21, 2025, the Financial Crimes Enforcement Network (FinCEN) announced that it will postpone the effective date of its anti-money laundering (AML) rule for investment advisers. The rule, which was previously set to take effect on January 1, 2026, will now be delayed until at least January 1, 2028.
FinCEN also confirmed that it is reexamining key elements of the rule and may narrow its scope before implementation. This signals the potential for substantive changes affecting which advisers will be covered and what compliance obligations will apply.
The rule, finalized in 2024, would extend AML program and suspicious activity reporting requirements to SEC-registered investment advisers and exempt reporting advisers, aligning their responsibilities with those of other financial institutions under the Bank Secrecy Act. The original goal was to address regulatory blind spots—particularly in the private fund space and across increasingly global investment platforms.
This two-year delay gives advisers more time to evaluate their internal compliance processes, systems, and vendor relationships. But with FinCEN now signaling that additional revisions are on the table, firms should stay alert to further developments and be prepared to adjust their compliance strategies as new guidance or rulemaking emerges.
We will continue monitoring updates from FinCEN and the Treasury Department. If you have questions about how this delay or potential changes to the rule might affect your firm, please reach out to us at SEC3 Compliance.
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