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On July 21, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) announced its intention to postpone by two years the effective date of the <a href="https://www.vedderprice.com/fincen-adopts-final-rule-extending-anti-money-laundering-compliance-program-requirements-to-certain-investment-advisers">final rule</a> that it adopted on August 28, 2024 which adds registered investment advisers (RIAs) and exempt reporting advisers (ERAs) to the definition of “financial institution” under the Bank Secrecy Act.  The final rule thereby extends certain anti-money laundering/countering the financing of terrorism (AML/CFT) program requirements to these advisers, requiring them to develop and implement a written AML/CFT program that is risk-based and reasonably designed to prevent the adviser from being used for money laundering, terrorist financing or other illicit finance activities. The final rule would have become effective, and compliance with the final rule would have been required by, January 1, 2026; however, FinCEN intends to postpone this to January 1, 2028.   The announcement of the final rule’s postponed effective date states:<blockquote class="wp-block-quote is-layout-flow wp-block-quote-is-layout-flow">
FinCEN recognizes…that the rule must be effectively tailored to the diverse business models and risk profiles of the investment adviser sector. FinCEN also recognizes that extending the effective date of the rule may help ease potential compliance costs for industry and reduce regulatory uncertainty while FinCEN undertakes a broader review of the [rule]. 
</blockquote>The announcement also states that during the postponement period, FinCEN intends to revisit the substance of the final rule through a future rulemaking process. In addition, FinCEN intends, together with the SEC, to revisit their May 13, 2024 jointly <a href="https://www.vedderprice.com/sec-and-fincen-propose-customer-identification-program-requirements-for-investment-advisers">proposed rule</a> under the Bank Secrecy Act that would impose new customer identification program (CIP) requirements on RIAs and ERAs.  Under the joint proposed rule, advisers would be required to establish, document and maintain written CIPs as part of their overall AML/CFT programs.The Treasury Department’s announcement is available <a href="https://home.treasury.gov/news/press-releases/sb0201">here</a>.

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FinCEN Postpones Effective Date of Investment Adviser Anti-Money Laundering Requirements

FinCEN Postpones Effective Date of Investment Adviser Anti-Money Laundering Requirements

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