The Office of the United States Trade Representative (USTR) has initiated a public consultation process in preparation for the upcoming joint review of the United States–Mexico–Canada Agreement (USMCA), scheduled for July 1, 2026. This process is mandated by Article 34.7 of the USMCA and section 611 of the USMCA Implementation Act, which require a comprehensive evaluation of the agreement’s operation and a determination by each party on whether to extend the agreement for an additional 16-year term.

Last month, we published an alert about the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) order providing exemptive relief for covered investment advisers from certain anti-money laundering and combating the financing of terrorism  program and other Bank Secrecy Act-related reporting, recordkeeping and information-sharing obligations (IA AML Rule) until January 1, 2028. The IA AML Rule, published by FinCEN as a final rule on September 4, 2024, is currently set to become effective on January 1, 2026. 
On September 22, 2025, FinCEN published a notice of proposed rulemaking to amend the IA AML Rule to delay its effective date by two years, from January 1, 2026 to January 1, 2028.