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The 2024 IA AML Rule, finalized August 28, 2024 (89 FR 72156, published September 4, 2024), redefined "financial institution" under the Bank Secrecy Act to include both SEC-registered investment advisers (RIAs) and Exempt Reporting Advisers (ERAs) — capturing roughly 15,000+ firms managing tens of trillions in client assets. Covered firms would have had to: (i) implement a written, risk-based AML/CFT program reasonably designed to prevent the firm from being used to facilitate money laundering or terrorist financing; (ii) appoint a designated AML compliance officer; (iii) train relevant personnel; (iv) obtain independent testing of the program; (v) file Suspicious Activity Reports (SARs) and Currency Transaction Reports (CTRs); and (vi) comply with information-sharing requests under §314(a)/(b). Original compliance date: January 1, 2026.
This final rule, signed in late December 2025 and published in the Federal Register on January 2, 2026 (FR Doc 2025-24184), pushes the compliance deadline back to January 1, 2028. The action is narrow in scope — it does not amend the substantive obligations of the underlying rule, only the date by which firms must be in compliance. FinCEN telegraphed in the preamble that it intends to use the additional two years to review and "appropriately tailor" the rule to the heterogeneity of the IA sector (private-fund advisers vs. wirehouse-affiliated wealth managers vs. ERAs running sub-$150m venture funds), and to coordinate with related Treasury and SEC rulemakings (notably the customer identification program joint rule with the SEC, also stalled).
The two-year delay is a deregulatory pullback rather than a true repeal — but it carries the practical effect of a multi-year reprieve for an industry that had begun building compliance infrastructure through 2025. It is consistent with the Trump 2.0 administration's broader regulatory-burden review and with the FinCEN BOI-rule narrowing (Mar 2025 interim final rule) earlier in the cycle.
ComplyAdvantage, ACA Group) lose a ~$200M+ near-term revenue pipeline tied to RIA/ERA onboarding through 2026, deferred to 2027.
fixed-cost compliance burden through 2027; this is the politically load-bearing constituency the delay protects.
FACT Coalition) has flagged the delay as creating a continuing AML blind spot for the private-fund channel — historically the vector flagged in the 2021 Treasury IA risk assessment.
the BOI interim final rule, and the broader Treasury deregulatory posture under the new administration — fits within post-2024-us-trade-reset.
out ERAs and sub-threshold private-fund advisers entirely, or apply a tiered risk-based framework?
and identity-theft red-flags rulemakings, several of which assumed AML/CFT infrastructure would be in place by 2026?
AML obligations on the IA channel during the federal pause?