FinCEN has formally delayed the long-anticipated anti-money laundering (AML) rule for investment advisers and exempt reporting advisers, pushing the effective date from January 1, 2026, to January 1, 2028.

The rule, finalized in 2024, will require covered advisers to establish AML and counter-terrorist financing programs, file suspicious activity reports, and comply with Bank Secrecy Act obligations. While the delay gives firms more time, the underlying expectations have not changed.

Why FinCEN Pressed Pause

According to FinCEN, the two-year delay is intended to give regulators additional time to refine the rule and better align requirements with adviser business models and risk profiles. It also allows for coordination with related proposals, including customer identification requirements for advisers.

Importantly, this is a timing adjustment, not a rollback. FinCEN has made clear that the AML framework for advisers is still moving forward.

What the Rule Will Ultimately Require

Once effective, the AML rule will require covered advisory firms to:

  • Implement a written, risk-based AML and counter-terrorist financing program
  • Designate an AML compliance officer
  • Conduct ongoing AML training
  • Establish independent testing of the AML program
  • File suspicious activity reports with FinCEN

For many firms, this will represent a significant expansion of compliance responsibilities.

Using the Delay Strategically

The two-year delay does not reduce regulatory expectations, but it does give compliance teams a valuable planning window. The priority now is preparation, not reaction. Establishing structure early will make implementation smoother and reduce exam risk once FinCEN’s AML requirements for advisory firms are fully in force.

Compliance teams should consider:

  • Assessing current controls: Review existing AML, fraud, and customer due diligence practices to identify gaps against expected BSA standards.
  • Documenting governance and ownership: Begin outlining who will own AML responsibilities and how escalation, reporting, and oversight will work in practice.
  • Planning for training and resources: AML compliance is not just a policy exercise. Firms will need trained staff, documented procedures, and repeatable workflows.
  • Monitoring related rulemaking: Additional guidance, including customer identification requirements, is still expected. Staying aligned will help avoid rework later.

Read FinCEN’s full press release, FinCEN Issues Final Rule to Postpone Effective Date of Investment Adviser Rule to 2028, to learn more.

Quest CE offers AML training designed for compliance teams, helping firms document expectations, educating staff, and preparing for future BSA obligations with confidence.

Explore our AML training catalog to start preparing today.