FinCEN issued a final rule (published in the Federal Register January 2, 2026) delaying the compliance date of the Investment Adviser AML/CFT Rule — originally published September 4, 2024 — from January 1, 2026 to January 1, 2028. The rule applies to registered investment advisers and exempt reporting advisers that would otherwise become subject to AML/CFT program and Suspicious Activity Report (SAR) obligations.
## Why the Delay
The delay followed a notice of proposed rulemaking issued in September 2025, in which FinCEN announced its intent to postpone and reconsider the rule. FinCEN stated the additional time will let it review and tailor the rule to the diverse business models and risk profiles within the investment adviser sector and coordinate with related rulemakings, including the investment adviser customer identification program (CIP) rule.
## Practical Effect
There are no 2026 obligations under the IA AML Rule. Firms are not required to have an AML/CFT program or SAR-filing capability in place on the original January 1, 2026 date. FinCEN has signaled the rule will be revisited rather than abandoned, so advisers should monitor for a revised rule and plan around an eventual January 1, 2028 compliance date.
> This delay removes a near-term compliance obligation many advisers had been preparing for. Firms that began building AML programs can pause large investments while keeping their work product for the eventual 2028 runway.