2025-18271Proposed Rule

FinCEN Pushes Back Adviser AML Rules to 2028

Published Date: 9/22/2025

Proposed 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 get ready before they have to follow the new rules and file suspicious activity reports. If you’re a registered or exempt reporting investment adviser, this delay means extra breathing room to comply without rushing or extra costs right now.

Analyzed Economic Effects

1 provisions identified: 1 benefits, 0 costs, 0 mixed.

AML Rules Delayed for Investment Advisers

FinCEN proposes moving the start date for new anti-money laundering (AML/CFT) program and suspicious activity report (SAR) filing rules for registered investment advisers and exempt reporting advisers from January 1, 2026 to January 1, 2028. If you are a registered or exempt reporting investment adviser, this gives you two extra years to prepare before you must follow the new rules and file SARs.

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Key Dates

Published Date
Comments Due
Effective Date
9/22/2025
10/22/2025
1/1/2028

Department and Agencies

Department
Independent Agency
Agency
Treasury Department
Financial Crimes Enforcement Network
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