The Financial Crimes Enforcement Network (FinCEN) has amended the Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT) Program and Suspicious Activity Report (SAR) Filing Requirements for Registered Investment Advisers and Exempt Reporting Advisers (the IA AML Rule) by delaying the rule’s effective date from January 1, 2026, to January 1, 2028.
As part of this delay, the date by which an investment adviser must develop and implement an AML/CFT program is extended to January 1, 2028.
The IA AML Rule requires covered investment advisers to establish AML/CFT programs, report suspicious activity, and keep relevant records, among other requirements.
The two-year delay gives FinCEN more time to review the IA AML Rule, and ensure that it is effectively tailored to the diverse business models and risk profiles of firms within the investment adviser sector. Delaying the effective date provides investment advisers with more time to come into compliance with the rule.
