FinCEN Delays IA AML Rule for RIAs and ERAs

On July 21 2025, the Financial Crimes Enforcement Network (FinCEN) confirmed it will postpone the effective date of its proposed anti-money laundering (AML) rule for investment advisers.

The rule, originally slated to take effect on January 1, 2026, would require registered investment advisers (RIAs) and exempt reporting advisers (ERAs) to implement AML programs, file suspicious activity reports, and comply with know your customer (KYC) requirements under the Bank Secrecy Act. It’s the most significant step yet in bringing private fund advisers into the core BSA framework.

FinCEN now says it expects to delay the effective date to January 1, 2028 - a two-year extension. The agency cited the “number and scope” of comments received during the rulemaking process, as well as the need to give firms sufficient lead time to build or adapt compliance programs. The final rule, including the updated timeline, has not yet been published.

Importantly, this is a delay, not a reversal. FinCEN has made clear that extending AML obligations to investment advisers remains a priority. The additional runway gives firms a window to align their global AML programs - reducing compliance risk, streamlining internal processes, and strengthening investor confidence in the long run.

Full press release here: https://home.treasury.gov/news/press-releases/sb0201