The Financial Crimes Enforcement Network is proposing to push back the effective date of its investor adviser rule by two years, which comes after the agency temporarily exempted investor advisers from complying with the regulation.
Under the investment adviser rule, covered advisers must implement risk-based anti-money laundering/countering the financing of terrorism programs, report suspicious activity to FinCEN and fulfill recordkeeping requirements. The rule was set to go into effect Jan. 1, 2026, but in August, the agency issued an order exempting covered advisers from compliance until Jan. 1, 2028.
FinCEN today issued a notice of proposed rulemaking to postpone the effective date of the rule to 2028. The agency said the delay will give it “an opportunity to reduce any unnecessary or duplicative regulatory burden and ensure the [investment adviser rule] strikes an appropriate balance between cost and benefit — while still adequately protecting the U.S. financial system and guarding against money laundering, terrorist financing and other illicit finance risks.”










