The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced today that it will postpone implementation of the Investment Adviser Anti-Money Laundering (AML) Rule, originally set to take effect on January 1, 2026. The new effective date will be January 1, 2028.

In addition to the two-year delay, FinCEN will reopen and reconsider the rule’s scope and requirements. The agency stated its intent to better tailor the rule to the diverse risk profiles and business models of registered investment advisers (RIAs) and exempt reporting advisers.

FinCEN also announced plans to revisit a separate proposed rule related to Customer Identification Program (CIP) requirements for investment advisers. These developments follow ADISA’s formal comment letter submitted in July 2024 to FinCEN and the SEC, which urged regulators to narrow the scope of the CIP proposal, tailor compliance requirements to actual risk exposure, and acknowledge the structural limitations of many advisory relationships in the alternative investment space.

What it Means for ADISA Members

• Two-Year Implementation Delay: The AML rule will now take effect in 2028, giving firms additional time to assess and prepare for future compliance obligations. 

• Revised Rulemaking Ahead: FinCEN will revisit both the IA AML Rule and the proposed CIP requirements. This provides a new opportunity for ADISA and its members to engage in the regulatory process and advocate for workable, risk-based standards.
  

• Temporary Regulatory Relief: FinCEN intends to issue exemptive relief to formalize the delay, reducing immediate compliance pressure and regulatory uncertainty.
  

• Planning Window: While the rule is delayed, firms should use this time to review their AML readiness and anticipate potential revisions as FinCEN and the SEC resume the rulemaking process.

ADISA will continue to monitor developments closely and provide updates and opportunities for member input as the rulemaking process resumes.