On July 21, FinCEN announced its intention to postpone the effective date of a final rule which would establish certain anti-money laundering requirements for investment advisers from January 1, 2026, to January 1, 2028. By treating certain SEC-registered investment advisers (RIAs) and exempt reporting advisers (ERAs) as “financial institutions” under the Bank Secrecy Act, the final rule would establish minimum standards for anti-money laundering and countering the financing of terrorism programs to be established by these investment advisers, as well as require the filing of suspicious activity reports for these RIAs and ERAs, among other changes.
FinCEN announced that the delayed effective date was necessary as it “appropriately balances regulatory costs and benefits” and seeks to tailor the rule to the investment adviser sector. The agency stated that it will revisit the rule in a future rulemaking process and reconsider proposed customer identification program requirements for investment advisers.
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