On July 21, 2025, the Financial Crimes Enforcement Network (FinCEN) announced that it is postponing the effective date of its anti-money laundering (AML) rule for investment advisers until January 1, 2028. This marks a notable shift from the previously planned 2026 implementation and signals that FinCEN is not only delaying enforcement but may also be reconsidering aspects of the rule’s scope.

Breaking Down the Postponement

FinCEN’s announcement reopens the AML rule for additional public comment, creating an opportunity to revisit its original design. According to the agency, the rule will undergo further evaluation to ensure it reflects the “diverse business models and risk profiles” found within the investment adviser space. FinCEN noted it will:

  • Reevaluate the scope of the AML rule to ensure it is appropriately tailored for investment advisers and exempt reporting advisers.
  • Collaborate with the SEC to revisit the jointly proposed Customer Identification Program (CIP) rule, which, if finalized, would impose identity verification and recordkeeping obligations on advisers similar to those required of other financial institutions.

These actions suggest that while AML regulation for investment advisers is still very much on the horizon, the final framework may differ meaningfully from what was initially proposed.

A Shift, Not a Retreat

The delay should not be interpreted as a reversal of FinCEN’s intention to regulate AML compliance within the advisory space. In fact, the extended timeline suggests a more comprehensive and coordinated rule may be on the horizon, especially as AML oversight continues to be a priority across financial services.

Regulators and institutional investors increasingly expect advisers to operate with a baseline level of AML diligence, regardless of whether a formal rule is in place. In that context, the delay offers time for thoughtful preparation, not permission to disengage.

How Firms Can Use This Time Wisely

For firms looking to stay ahead of the curve, this two-year extension can be an opportunity to evaluate internal processes and make progress toward future compliance:

  • Monitor regulatory developments. FinCEN is expected to issue revised proposals and guidance in the coming year. Firms should be prepared to adapt quickly once a final rule is set.
  • Assess potential risk exposure. Consider your firm’s structure, client base, and any affiliations (e.g., with broker-dealers or banks) that may already require AML protocols.
  • Begin foundational planning. If your firm has not yet addressed AML internally, use this time to explore frameworks, partners, or technologies that can support you when the rule goes into effect.

Looking Ahead

FinCEN’s decision to delay implementation offers firms time to prepare—but it also signals that the final rule may evolve in meaningful ways. Rather than viewing this postponement as a pause, firms should see it as a strategic planning window.

With scope changes and joint rulemaking still in development, staying informed and engaged will be key. Firms that use this time to assess their risk exposure, explore AML frameworks, and monitor regulatory updates will be well positioned—not just to meet future obligations, but to strengthen their overall compliance posture in the process.

At Quest CE, we’ll continue to monitor FinCEN’s updates and provide resources to help investment advisers meet AML obligations with confidence and clarity.