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AMLSeptember 25, 2025

FinCEN Formally Proposes Two-Year Delay of Investment Adviser AML Rule

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FinCEN has formally proposed postponing the investment adviser anti-money laundering rule effective date from January 2026 to January 2028. While the delay provides additional runway, firms are encouraged to continue program development.

ICS advises financial institutions navigating regulatory changes of this type. If your firm needs to assess the impact of this development on your compliance program, contact us to discuss.

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ICS Insights provides periodic regulatory commentary for financial institutions. Our analysis focuses on developments that materially affect compliance obligations across the institutions we serve.

Related practice areaAML & Financial Crimes →Program design, monitoring, and ongoing compliance for high-risk environments.

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