Overview

• The Sept. 22 notice would move the effective date from Jan. 1, 2026 to Jan. 1, 2028 for registered investment advisers and exempt reporting advisers.
• FinCEN opened a 30-day comment period on the timing proposal, with submissions due Oct. 22, 2025.
• The proposal does not change the rule’s substance, which treats covered advisers as Bank Secrecy Act financial institutions.
• Covered firms would be required to maintain AML/CFT programs, file SARs and CTRs, keep fund transmittal records, and participate in BSA information sharing.
• FinCEN says the delay allows review of tailoring across diverse business models and easing near-term costs, while Treasury’s 2024 risk assessment continues to anchor the need for an AML framework.