July 22, 2025

Great news! It has been widely speculated that the investment adviser AML Rule would not go into effect as scheduled on January 1, 2026.  That speculation has become reality as FinCEN announced on July 21 that it intends to issue exemptive relief to delay the effective date of the rule for 2 years to January 1, 2028.  When announcing this delay, FinCEN stated it intends to revisit the scope and substance of the rule at a future date and also intends to work with the SEC to revisit the joint CIP Rule proposal (which had not yet been adopted), which would have established Customer Identification Program requirements for investment advisers.  While the ultimate future of this controversial rule remains unclear, at least advisers have some short-term certainty after FinCEN’s announcement.