What happened?
On July 21, 2025, the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) announced it is postponing the compliance date for the final AntiMoney‑ Laundering/Countering the Financing of Terrorism rule applicable to Registered Investment Advisory firms (RIAs) and Exempt Reporting Advisers. Instead of January 1, 2026, firms now have until January 1, 2028, to comply—and FinCEN is reopening the rule for reassessment (FinCEN.gov).
What are Anti-Money Laundering (AML) Procedures?
First, let’s talk AML generally. AML procedures are a set of policies, controls, and practices used by financial institutions and other regulated entities to detect, prevent, and report money laundering and related financial crimes, including terrorism financing.
Why This Matters
1. Compliance Relief
Firms, especially smaller ones, had flagged concerns about tight deadlines and hefty costs. This two-year extension gives breathing room to adapt and get ready for compliance.
2. Rule Reassessment Underway
FinCEN plans to review and potentially refine key aspects like AML program requirements, Suspicious Activity Report (SAR) thresholds, and coordination with the Security and Exchange Commission’s (SEC) Customer Identification Program proposal.
3. Strong Industry Support
Advisor advocacy groups, such as the Investment Adviser Association and the Venture Capital Association, applauded the move, acknowledging the need for a tailored approach rather than a one-size-fits-all regime.
What Advisors Should Do Now
|
Action |
Why It Matters |
| Update AML risk assessments | Use the extended timeline to ensure programs reflect your firm’s size, client base, and risk profile |
| Map compliance processes | Clearly document SAR thresholds, beneficial ownership procedures, and customer identification steps |
| Track rulemaking activity | Stay engaged in the process, as FinCEN and SEC will open the rule again for public comments |
| Position for change | A more tailored rule could reduce redundant or irrelevant requirements, so it’s important to be ready to adapt |
The Bottom Line
The delay isn’t a signal to drop AML preparedness—it’s a strategic pause. Regulators remain committed to strengthening the AML framework for Registered Investment Advisory firms, but now will do so with better balance. Firms that use this time to build robust, scalable processes will be well prepared‑ and compliant when the rule takes effect in 2028.
Need advisory support? Endeavor Retirement partners with firms to streamline complex governance, providing hands-on support to build tailored solutions.
Let us know if you’d like deeper insight into any of these steps or to better understand how Endeavor Retirement and Endeavor Law can assist!