Treasury Postpones Effective Date of Investment Adviser AML Rule; Signals Broader Reassessment of Regulatory Framework

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) announced today its intent to postpone the effective date of its final rule imposing anti-money laundering (“AML”) and countering the financing of terrorism (“CFT”) requirements on investment advisers (the “IA AML Rule”). The new anticipated effective date is January 1, 2028, replacing the original date of January 1, 2026. In parallel, FinCEN indicated that it plans to revisit the scope and substance of the IA AML Rule through a renewed rulemaking process. The agency cited the need to appropriately tailor regulatory obligations to the varied business models and risk profiles present across the investment adviser sector, while also balancing implementation costs and regulatory clarity.