August 8, 2025

FinCEN Issues Order Delaying Effective Date of Investment Adviser Rule

John Babcock, Jason Daniel, Alexis Guinan, Nnedinma Ifudu Nweke, James Munsell, Barbara Niederkofler, Atsushi Oshima, Brian Rafferty, Andrew Schlossberg, William Wetmore

Akin Gump Strauss Hauer & Feld LLP

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Akin Gump Strauss Hauer & Feld LLP

Following an earlier announcement on July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), on August 5, 2025, issued an Exemptive Relief Order (“Order”) to delay for two years, from January 1, 2026 to January 1, 2028, the effective date of the final rule Anti-Money Laundering/Countering the Financing of Terrorism Program and Suspicious Activity Report Filing Requirements for Registered Investment Advisers and Exempt Reporting Advisers (the “Investment Adviser Rule”).
FinCEN, in its earlier announcement, indicated its intent to “revisit the substance” of the Investment Adviser Rule through a future rulemaking process. FinCEN has, in the latest Order, indicated it intends to review the Investment Adviser Rule to “ensure it strikes an appropriate balance between cost and benefit,” is consistent with the Trump administration’s “deregulatory agenda” and is “effectively tailored to the diverse business models and risk profiles of the investment adviser sector.”
FinCEN indicated in the Order its intent to propose, through a rulemaking process, a new effective date for the Investment Adviser Rule no earlier than January 1, 2028.

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