Treasury Delays AML Rules for Investment Advisers by Two Years
Published Date: 1/2/2026
Rule
Summary
FinCEN is pushing back the start date for new anti-money laundering rules for investment advisers by two years, from January 1, 2026, to January 1, 2028. This gives advisers more time to set up programs to spot and report suspicious money moves. If you’re a registered or exempt reporting investment adviser, this delay means extra breathing room before these important rules kick in.
Analyzed Economic Effects
4 provisions identified: 4 benefits, 0 costs, 0 mixed.
Estimated Near-Term Cost Savings
FinCEN estimates that delaying the rule will reduce certain direct compliance costs by about $1.45 billion (pro forma). The agency reports net present value savings of approximately $1,453.63 million at a 7% discount rate and $1,523.60 million at a 3% discount rate, with annualized savings of $183.01 million (7%) and $153.06 million (3%).
IA AML Rule Effective Date Delayed
FinCEN officially pushed back the start of the anti-money laundering (AML/CFT) and suspicious-activity reporting requirements for covered investment advisers from January 1, 2026 to January 1, 2028. If you are a registered or exempt reporting investment adviser, you now have until January 1, 2028 to develop and implement an AML/CFT program that meets the rule's requirements.
Postponed Information Collections For Customers
FinCEN estimates that, among projected new customers of covered investment advisers, about 1.5 million or 1.8 million customers would be expected to incur the information-collection burden assigned to legal-entity customers under the IA AML Rule. The agency also estimates increases of about 241,849 or 483,699 expected respondents in 2026 or 2028, respectively, in comparison scenarios.
Small Entities Not Significantly Impacted
FinCEN certifies under the Regulatory Flexibility Act that this two-year delay will not have a significant economic impact on a substantial number of small entities. The agency estimates small covered investment advisers make up about 1.9% (updated estimate under 3%) of the covered population and identified 391 small covered IAs in its baseline.
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