FinCEN Postpones Effective Date of Anti-Money-Laundering Rule for Investment Advisers and Exempt Reporting Advisers

On July 21, 2025, the U.S. Department of the Treasury Financial Crimes Enforcement Network (FinCEN) announced that it intends to postpone the effective date of the final rule requiring anti-money-laundering (AML) programs for certain investment advisers (the IA AML Rule). The rule, previously scheduled to take effect on January 1, 2026, will now be delayed until January 1, 2028.

Next Steps

According to FinCEN’s press release, the agency will issue formal exemptive relief to provide regulatory certainty and ensure that affected firms are not required to comply by the original 2026 deadline. This extension applies to both investment advisers (IAs) and exempt reporting advisers (ERAs) that fall within the scope of the IA AML Rule.

In addition, FinCEN noted that it plans to revisit both the substance and the scope of the IA AML Rule through a new rulemaking process. Separately, FinCEN — working jointly with the Securities and Exchange Commission — intends to reexamine the proposed Customer Identification Program (CIP) rule that would impose client verification requirements on investment advisers.

What This Means for Advisers

IAs and ERAs should take the following steps:

• Monitor future rulemaking developments related to both the IA AML Rule and the FinCEN/SEC joint CIP proposal.
• Engage in the comment process when opportunities arise to help shape rules that reflect industry practices and the operational realities of the investment adviser sector.
• Review compliance programs proactively as the regulatory landscape continues to evolve.

Sidley’s Investment Funds and Regulatory teams are closely tracking these developments. Please contact us if you have any questions or would like assistance in preparing for future AML or CIP requirements.