
FinCEN Delayed the Investment Adviser AML Rule to 2028. The Clock Is Still Running.
FinCEN moved the investment adviser AML rule's effective date from January 1, 2026 to January 1, 2028, covering roughly 20,000 SEC-registered advisers and exempt reporting advisers. Here's what the rule requires — SARs at $5,000, CTRs above $10,000, travel-rule recordkeeping at $3,000 — and a 24-month plan to build the program before the deadline.










