22 Sep 2025

⏳Delay Proposed for AML/CFT Requirements for Investment Advisers

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

Summary

FinCEN is proposing to amend the Anti-Money Laundering/ Countering the Financing of Terrorism (AML/CFT) Program and Suspicious Activity Report (SAR) Filing Requirements for Registered Investment Advisers and Exempt Reporting Advisers (IA AML Rule) to delay the effective date by two years. The IA AML Rule is effective on January 1, 2026. This proposal seeks to amend the effective date to January 1, 2028.

Agencies

  • Treasury Department
  • Financial Crimes Enforcement Network

Business Impact ?

$$$ - High

The proposed rule delays the effective date of the Anti-Money Laundering/Countering the Financing of Terrorism requirements for investment advisers, impacting compliance and regulatory obligations. Businesses could benefit from reduced compliance costs estimated at $1.45 billion, freeing resources for other investments.

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