What This Means for Advisers:

FinCEN has formally proposed to delay the effective date of the investment adviser AML rule from January 1, 2026, to January 1, 2028.

The amendment itself is narrowly tailored to delaying the effective date, leaving the substance of the rule intact. However, FinCEN has made clear that it may propose further substantive changes before the rule takes effect.

Advisers should treat this as both regulatory relief and a signal that the contours of their future AML obligations remain unsettled.

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On September 19, 2025, the Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (NPRM) that would amend the investment adviser anti-money laundering (AML) rule adopted in 2024. The proposed amendment wou

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