News & Analysis as of July 30, 2025

FinCEN › Regulatory Requirements

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The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury charged with detecting and combatting illegal activity within the financial system. FinCEN detects evidence of money laundering, terrorist financing and other financial crimes by collecting, monitoring, and analyzing financial transaction data. Such data is disseminated to both domestic and international law enforcement agencies. less -

Treasury Postpones Effective Date of Investment Adviser AML Rule, Plans Revisions

Wilson Sonsini Goodrich & Rosati on 7/30/2025

The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has announced that it intends to postpone the effective date of the final rule establishing anti-money laundering (AML) and suspicious...more

FinCEN Delays Enforcement of Investment Adviser AML/CFT Rule

Alston & Bird on 7/29/2025

Our Financial Services and Investment Funds Teams examine the delay by the Financial Crimes Enforcement Network (FinCEN) of the effective date for the Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT)...more

FINCEN Postpones AML/CFT Rules for Investment Advisers Until 2028 and Revisits Scope of Such Rules

BCLP on 7/29/2025

FinCEN’s announcement clearly reflected its sensitivity to industry concerns. It acknowledged that AML/CFT Rules “must be effectively tailored to the diverse business models and risk profiles of the investment adviser...more

Financial Institutions Permitted to Use Third Parties to Collect Customers’ Taxpayer Identification Numbers for Identity...

Alston & Bird on 7/28/2025

Our Financial Services and White Collar, Government & Internal Investigations Teams examine the Financial Crimes Enforcement Network’s new customer identification program (CIP) exemption that allows banks and credit unions to...more

[Webinar] Targeted: How FinCEN's Fentanyl Fight Is Reshaping U.S.–Mexico Financial Compliance - August 7th, 11:00 am - 12:00 pm ET

Lowenstein Sandler LLP on 7/28/2025

Join Lowenstein Sandler and Santamarina + Steta for a timely webinar exploring the legal and compliance implications of recent U.S. Treasury actions under the FEND Off Fentanyl Act. The session, featuring Lowenstein's Robert...more

FinCEN Announces It Will Provide Two-Year Extension of the AML Rule Compliance Date for Registered Investment Advisers and Exempt...

King & Spalding on 7/25/2025

Registered Investment Advisers (RIAs) and Exempt Reporting Advisers (ERAs) were less than six months away from the requirement to implement an anti-money laundering and countering the financing of terrorism (AML/CFT) program...more

FinCEN Delays And Intends To Revisit Investment Adviser Final Rule

Ballard Spahr LLP on 7/25/2025

We blogged last year about the Final Rule issued by the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) extending Anti-Money Laundering/Countering the Financing of Terrorism (AML/CFT)...more

FinCEN Announces Postponement and Reopening of the Investment Adviser Anti-Money Laundering Rule

Dinsmore & Shohl LLP on 7/25/2025

On July 21, 2025 the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to postpone the effective date of the final rule establishing the investment adviser anti-money...more

FinCEN Postpones New AML Rule for Investment Advisers

Latham & Watkins LLP on 7/25/2025

On July 21, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced that it intends to postpone the effective date of the final rule concerning the Anti-Money Laundering/Countering...more

Treasury and FinCEN Announce Delay of IA–AML Rule Implementation to January 1, 2028

Snell & Wilmer on 7/24/2025

On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to postpone the effective date of the Anti‑Money Laundering/Countering the Financing of Terrorism...more

FinCEN Delays Effective Date of Investment Adviser Rule and Intends to Revisit the SEC Customer Identification Program Rule for...

Akin Gump Strauss Hauer & Feld LLP on 7/24/2025

In September 2024, FinCEN issued the Investment Adviser Rule, which aims to “address ongoing illicit finance risks, threats, and vulnerabilities posed by criminals and foreign adversaries that exploit the U.S. financial...more

FinCEN Postpones Investment Adviser AML Requirements, Buying Time for Revisions

Seward & Kissel LLP on 7/24/2025

On July 21, 2025, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) announced that it was delaying the effective date of its final rule establishing Anti-Money Laundering/Countering the Financing...more

Investment adviser anti-money laundering rule postponed and reopened for further review

Eversheds Sutherland (US) LLP on 7/24/2025

On July 21, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to delay the effective date for certain investment advisers to implement anti-money...more

United States: AML Reprieve for Investment Advisers

K&L Gates LLP on 7/23/2025

On July 21, 2025, the Financial Crimes Enforcement Network (FinCEN) announced that it is delaying the effective date of the investment adviser anti-money laundering rule (IA AML Rule) for two years from 1 January 2026 to 1...more

FUNDamentals – FinCEN Delays Investment Adviser AML Rule Until 2028, Signals Revisions to Scope

Troutman Pepper Locke on 7/23/2025

On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to delay the effective date of the final rule imposing anti-money laundering (AML) obligations on...more

Treasury to Delay Investment Adviser AML Rule to 2028, Announces Intent to Reconsider AML and CIP Rules

Proskauer Rose LLP on 7/23/2025

On July 21, 2025, the Department of the Treasury announced a two-year postponement of the much-anticipated anti-money laundering (AML) rule, adopted by Treasury’s Financial Crimes Enforcement Network (FinCEN) in 2024,...more

FinCEN to Postpone Investment Adviser Anti-Money Laundering Rule

Cooley LLP on 7/23/2025

On July 21, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to (1) postpone until January 1, 2028, the effective date of the final anti-money laundering rule...more

FinCEN Postpones Effective Date of AML/CFT Rule for Investment Advisers

Morrison & Foerster LLP on 7/23/2025

On July 21, 2025, the U.S. Department of the Treasury’s (“Treasury”) Financial Crimes Enforcement Network (FinCEN) announced it will delay the effective date of the final rule establishing anti-money laundering/countering the...more

Bank Secrecy Act Postponed for Investment Advisers and Exempt Reporting Advisers

Lowenstein Sandler LLP on 7/23/2025

On July 21, the United States Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intent to postpone compliance with new regulatory requirements imposing certain anti-money laundering...more

BREAKING: FinCEN Postpones Effective Date of Investment Adviser AML Rule

Mayer Brown on 7/22/2025

Earlier yesterday, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to postpone the effective date of the final rule establishing Anti-Money Laundering/Countering the...more

FinCEN Delays AML Program Rule for Investment Advisers

Ropes & Gray LLP on 7/22/2025

On July 21, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) announced that it intends to delay implementation of its final rule, Anti-Money Laundering/Countering the Financing of Terrorism...more

The Anti-Money Laundering Quarterly - July 2025

Morrison & Foerster LLP on 7/17/2025

Designed for busy in-house counsel and compliance professionals, this newsletter summarizes some of the most important domestic and international Anti-Money Laundering (AML) regulatory and enforcement developments from the...more

IRS roundup: June 18 – July 11, 2025

McDermott Will & Emery on 7/16/2025

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for June 18, 2025 – July 11, 2025. “One Big Beautiful Bill Act” tax provisions - On July 4, 2025, US President Donald...more

Application of New Anti-Money Laundering Regulations to Advisers to Private Funds

Robinson Bradshaw on 7/15/2025

On Sept. 4, 2024, the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) published a final rule imposing new anti-money laundering (AML) and countering the financing of terrorism (CFT) requirements on...more

Midyear Momentum, July 2025 - FinCEN Uses the FEND Off Fentanyl Act for First Time To Prohibit Funds Transfers With Three Mexican...

Cadwalader, Wickersham & Taft LLP on 7/11/2025

On June 25, 2025, FinCEN announced its first orders under the 2024 FEND Off Fentanyl Act, finding that three Mexican financial institutions—CIBanco S.A. Institución De Banca Multiple (“CIBanco"), Intercam Banco S.A.,...more

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FinCEN › Regulatory Requirements

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