AML Rule for Investment Advisers Postponed to 2028: FinCEN and SEC Revisit Requirements

On July 21, 2025, the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of the Treasury, announced its intention to postpone the effective date of the final anti-money laundering (AML) rule for registered investment advisers. The compliance deadline, originally set for January 1, 2026, is now expected to be delayed until January 1, 2028.

FinCEN stated it plans to issue appropriate exemptive relief to formally extend the compliance date. However, the announcement goes beyond timing—FinCEN confirmed that it intends to revisit the scope and substance of the AML rule and, in coordination with the Securities and Exchange Commission (SEC), also plans to reconsider the recently proposed Customer Identification Program (CIP) rule.

“FinCEN intends to provide the IA sector with regulatory certainty by issuing appropriate exemptive relief delaying the effective date. During the delayed effective date, FinCEN intends to revisit the substance of the IA AML Rule through a future rulemaking process and, together with the Securities and Exchange Commission, also intends to revisit the joint proposed rule establishing customer identification program rule requirements for investment advisers.”— U.S. Treasury Press Release, July 21, 2025

What this means

The compliance date for the AML rule has been formally delayed, but this remains a significant regulatory development for investment advisers. FinCEN and the SEC have made it clear that further rulemaking is expected—both to revisit the AML rule’s substance and to reconsider the proposed Customer Identification Program (CIP) requirements.

Firms should understand that AML and CIP obligations are still expected in the future. Monitoring for additional guidance is essential. Understanding how FinCEN and the SEC intend to shape and implement these rules will be key to preparing for future compliance expectations.

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