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ARTICLE · 16 JANUARY 2026

FinCEN Finalizes 2028 Compliance Date For Adviser AML Programs

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On December 31, 2025, the US Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) finalized a two‑year delay of the effective date for the anti-money...

United StatesGovernment, Public Sector
Adam Bolter
Adam Bolter
Michael Didiuk
Michael Didiuk
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On December 31, 2025, the US Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) finalized a two‑year delay of the effective date for the anti-money laundering/counter-financing of terrorism (AML/CFT) program and suspicious activity reporting (SAR) filing requirements applicable to certain investment advisers. FinCEN has pushed the compliance date from January 1, 2026, to January 1, 2028.

Background

The 2024 adviser AML/CFT rule defined certain registered investment advisers and exempt reporting advisers as "financial institutions" under the Bank Secrecy Act, subjecting them to AML/CFT program requirements, SAR reporting, and related recordkeeping (Adviser AML Rule). For more information about the Adviser AML Rule, see our prior publication.

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