News & Analysis as of

FinCEN Rulemaking Process

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... more +
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 -
Vedder Price

FinCEN Postpones Effective Date of Investment Adviser Anti-Money Laundering Requirements

Vedder Price on

On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to postpone by two years the effective date of the final rule that it adopted on August 28, 2024...more

Sheppard Mullin Richter & Hampton LLP

FinCEN Warns Financial Institutions of Illicit Activity at Crypto Kiosks

On August 4, 2025, the Financial Crimes Enforcement Network (FinCEN) issued a notice warning financial institutions about escalating illicit activity involving convertible virtual currency (CVC) kiosks. The notice cites...more

Akin Gump Strauss Hauer & Feld LLP

FinCEN Issues Order Delaying Effective Date of Investment Adviser Rule

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,...more

Orrick, Herrington & Sutcliffe LLP

FinCEN delays compliance with investment adviser rule by two years

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...more

McGuireWoods LLP

FinCEN Hits Pause: AML Rule for Investment Advisers Delayed

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In a move to balance regulatory efficiency and cost, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) officially announced on July 21, 2025, that it will postpone the effective date, from...more

ArentFox Schiff

Treasury Postpones Effective Date of Investment Adviser AML Rule

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On July 21, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced a two-year postponement of the Anti-Money Laundering (AML)/Countering the Financing of Terrorism (CFT) Program and...more

Goodwin

FinCEN to Postpone Effective Date and Reopen Anti-Money Laundering Rule for Investment Advisers

Goodwin on

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

Haynes Boone

FinCEN Announces Intention to Postpone Effective Date of Anti-Money Laundering Rule for Registered Investment Advisers and Exempt...

Haynes Boone on

FinCEN will work through the rulemaking process to formally extend the IA AML Rule effective date and intends to provide the IA sector with regulatory certainty by issuing appropriate exemptive relief delaying the effective...more

Fenwick & West LLP

FinCEN Delays Investment Adviser AML/CFT Rule to January 2028: What Fund Managers Should Know

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On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced that it intends to postpone the effective date of its 2024 investment advisor AML rule for registered investment...more

BCLP

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

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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

King & Spalding

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

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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

Snell & Wilmer

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

Snell & Wilmer on

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

Akin Gump Strauss Hauer & Feld LLP

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

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

Orrick, Herrington & Sutcliffe LLP

FinCEN Postpones Investment Adviser AML Rule Until 2028

On July 21, the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) announced that it was postponing and reevaluating the anti-money laundering (AML) rule for investment advisers (Adviser AML...more

Eversheds Sutherland (US) LLP

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

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

Troutman Pepper Locke

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

Troutman Pepper Locke on

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

Proskauer Rose LLP

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

Proskauer Rose LLP on

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

Cooley LLP

FinCEN to Postpone Investment Adviser Anti-Money Laundering Rule

Cooley LLP on

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

Morrison & Foerster LLP

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

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

Ropes & Gray LLP

FinCEN Delays AML Program Rule for Investment Advisers

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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

Greenberg Glusker LLP

Out with a Whimper: FinCEN Issues Interim Final Rule on Corporate Transparency Act, Narrows BOI Reporting Requirements

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On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) announced an interim final rule, which was officially published in the Federal Register on March 26, 2025, removing the requirement for U.S. companies and...more

Snell & Wilmer

The (Almost) End of the Corporate Transparency Act

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In a whirlwind attempt to follow the roller coaster actions in the courts, the U.S. Congress, and FinCEN’s administrative efforts, Snell & Wilmer has worked to keep clients updated with the drama-filled developments of the...more

Epstein Becker & Green

CTA Interim Final Rule Eliminates Requirements for U.S. Companies and U.S. Individuals to File Beneficial Ownership Reports

On March 26, 2025, the Financial Crimes Enforcement Network (FinCEN), in an action that was promised earlier in March, issued an interim final rule (the “Interim Rule”) that removes all requirements for U.S. companies and...more

Cozen O'Connor

FinCEN Exempts US Entities and Persons from CTA

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On March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) adopted an interim final rule (Rule) exempting U.S. companies previously subject to the reporting requirements under the Corporate Transparency Act (CTA)...more

Ropes & Gray LLP

FinCEN Significantly Narrows Corporate Transparency Act Reporting Requirements

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On March 21, the U.S. Treasury Department’s Financial Crimes Enforcement Network (“FinCEN”) published an interim final rule (the “March 21 Rule”) that: Narrows (significantly) the beneficial ownership information (“BOI”)...more

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