Today, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to postpone the effective date of the final rule establishing Anti-Money Laundering/Countering the Financing of Terrorism Program and Suspicious Activity Report Filing Requirements for Registered Investment Advisers and Exempt Reporting Advisers (the “IA AML Rule”) and to revisit the scope of the IA AML Rule at a future date.  FinCEN anticipates delaying the effective date of the IA AML Rule from January 1, 2026, until January 1, 2028. In the meantime, we will continue to monitor FINCEN’s rulemaking process to ensure the effective date is extended and determine how and whether the IA AML Rule will impact our clients.

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