Treasury Postpones IA AML Rule

Big New Today

Rule: Anti-Money Laundering/Countering the Financing of Terrorism Program and Suspicious Activity Report Filing Requirements for Registered Investment Advisers and Exempt Reporting Advisers

Timeline Change:

• Original effective date: January 1, 2026

• New effective date: January 1, 2028 (2-year delay)

Regulatory Actions:

• FinCEN intends to provide exemptive relief delaying the effective date

• Substantive rule review and potential revision during delay period

• Joint proposed Customer Identification Program rule with SEC also under review

Compliance Planning Impact:

• Immediate relief: 2-year implementation runway extension

• Ongoing uncertainty: Rule scope may change during review period

• Dual tracking needed: Monitor both exemptive relief and future rulemaking

Next Steps:

• Watch for formal exemptive relief issuance

• Track future rulemaking developments

• FinCEN recognizes rule must be effectively tailored to diverse business models and risk profiles - expect more targeted requirements

Source: Treasury Press Release SB0201 - https://home.treasury.gov/news/press-releases/sb0201