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.

As we’ve written previously, direct selling companies are facing a wave of lawsuits, primarily in California, claiming that distributors do not qualify as independent contractors and instead are misclassified employees. Just recently, however, a California court refused to certify a class on these claims—an important outcome for all direct sellers.