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.

Last year in September, we published an alert about the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) final rule, which would have imposed certain anti-money laundering and combating the financing of terrorism (AML/CFT) program and other Bank Secrecy Act-related obligations on investment advisers (IA AML Rule) effective January 1, 2026.