News & Analysis as of

Suspicious Activity Reports (SARs) Rulemaking Process Anti-Money Laundering

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

McGuireWoods LLP on

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

ArentFox Schiff on

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

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

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

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

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

Troutman Pepper Locke

Investment Management Update - Q1 2024

Troutman Pepper Locke on

This update covers legal developments and regulatory news for funds, their advisers, and industry participants for the quarter ended March 31. Rulemaking and Guidance: • SEC Adopts Reforms Relating to Investment Advisers...more

Sheppard Mullin Richter & Hampton LLP

Treasury Announces Renewed Push for Investment Adviser AML Rules in Q1 2024

The United States Department of the Treasury has announced that it is working to address what it perceives as money laundering risks associated with investment advisers. Specifically, the agency asserts that absent consistent...more

Ballard Spahr LLP

FinCEN Provides Key Updates on Rulemaking Agenda Timeline

Ballard Spahr LLP on

Without much fanfare, the Financial Crimes Enforcement Network (FinCEN) published in June its Spring 2023 Rulemaking Agenda, which provides proposed timelines for upcoming key rulemakings projected throughout the rest of...more

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